Hollabaugh v. MRO Corporation

CourtCourt of Appeals of Maryland
DecidedJuly 10, 2025
Docket27/24
StatusPublished

This text of Hollabaugh v. MRO Corporation (Hollabaugh v. MRO Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hollabaugh v. MRO Corporation, (Md. 2025).

Opinion

Janice Hollabaugh v. MRO Corporation, No. 27, September Term, 2024.

CONFIDENTIALITY OF MEDICAL RECORDS ACT – STATUTORY STANDING – MOTION TO DISMISS The Confidentiality of Medical Records Act provides that a “health care provider or any other person who knowingly violates any provision” of the Act is “liable for actual damages.” Although the petitioner and cross-respondent was not the party who made the request or paid the fee to the provider, she alleged in her complaint that she reimbursed her attorney in full for the payment made. At the motion to dismiss stage, the petitioner’s allegations created a reasonable inference of facts sufficient to support her standing.

CONFIDENTIALITY OF MEDICAL RECORDS ACT – STATUTORY INTERPRETATION – FEE FOR RETRIEVAL AND PREPARATION The Confidentiality of Medical Records Act seeks to protect the privacy of patients and maintain the confidentiality of medical records by establishing rules for health care providers’ maintenance and disclosure of those records. As part of that statutory scheme, the Act establishes that the providers may charge a reasonable cost-based fee to certain persons for copying and providing information requested, and it authorizes and caps certain types of fees, including “a preparation fee not to exceed $22.88 for medical record retrieval and preparation.” The plain meaning and statutory context of that provision confirm that health care providers may not charge a preparation fee for a search that does not result in copying and providing the information requested. Circuit Court for Baltimore County Case No. C-03-CV-22-003166 Argued: April 7, 2025

IN THE SUPREME COURT

OF MARYLAND

No. 27

September Term, 2024

______________________________________

JANICE HOLLABAUGH

v.

MRO CORPORATION

Fader, C.J., Watts, Booth, Biran, Gould, Eaves, Killough,

JJ. ______________________________________

Opinion by Fader, C.J. ______________________________________

Pursuant to the Maryland Uniform Electronic Legal Filed: July 10, 2025 Materials Act (§§ 10-1601 et seq. of the State Government Article) this document is authentic.

2025.07.10 14:14:54 -04'00' Gregory Hilton, Clerk The General Assembly enacted the Confidentiality of Medical Records Act,

Md. Code Ann., Health-Gen. §§ 4-301 – 4-310 (2023 Repl.; 2024 Supp.), to protect the

privacy of patients and maintain the confidentiality of medical records by establishing rules

for the maintenance and disclosure of those records. As part of that scheme, the

Confidentiality Act establishes a right of access for certain persons who request in writing

to see, receive, or copy records. The Act permits health care providers to charge limited

fees to certain persons for copying and providing the information requested, one of which

is a “preparation fee” not to exceed $22.88 for medical record “retrieval and preparation.”

At issue here is whether a health care provider may charge that fee for conducting a search

that does not lead to the production of any medical records. We hold that the

Confidentiality Act does not permit a fee in that circumstance.

BACKGROUND

A. Factual Background 1

In February 2020, Janice Hollabaugh, the petitioner and cross-respondent,

authorized her attorney to request her medical records from a health care provider for use

in pursuing personal injury claims. That provider contracted with MRO Corporation, the

respondent and cross-petitioner, to fulfill the request. MRO then sent Ms. Hollabaugh’s

attorney a document titled “Cancellation Invoice.” The ambiguously written document

1 Because Ms. Hollabaugh appeals the circuit court’s grant of a motion to dismiss, we “assume the truth of, and view in a light most favorable to the non-moving party, all well-pleaded facts and allegations contained in the complaint, as well as all inferences that may reasonably be drawn from them[.]” RRC Northeast, LLC v. BAA Maryland, Inc., 413 Md. 638, 643 (2010). states: “Your request for Medical Records has been cancelled. The medical facility has

completed the search and retrieval of the requested records. This invoice is for the

Search/Retrieval Fee if applicable in your state.” It is unclear why MRO identified the

request as being canceled, but it is plain from the allegations in the complaint that the

request was canceled by MRO and not by Ms. Hollabaugh or her attorney.

Although MRO did not produce any records, it charged Ms. Hollabaugh’s counsel

a fee of $22.88 “for searching for her Medical Records.” Ms. Hollabaugh’s attorney paid

the fee, and she reimbursed him in full.

B. Procedural History

In August 2022, Ms. Hollabaugh filed a putative class action lawsuit in the Circuit

Court for Baltimore County. Count I of the first amended complaint alleges that the fee

MRO charged for searching for her medical records violates § 4-304(c) of the Health-

General Article, which is the provision of the Confidentiality Act authorizing, among other

things, the $22.88 fee for record “retrieval and preparation.” 2 She seeks damages equal to

the alleged overpayment.

After an unsuccessful attempt to remove the case to federal court, MRO moved to

dismiss, arguing among other things that § 4-304(c) authorizes a fee for records searches

that do not result in the production of records, and that Ms. Hollabaugh lacks standing to

2 The complaint also alleges violations of the Maryland Consumer Protection Act and the Maryland Consumer Debt Collection Act, and requests a declaratory judgment and “money had and received,” in addition to actual damages. Those claims are not at issue in this appeal. 2 sue because her attorney, not Ms. Hollabaugh herself, made the records request and paid

the fee. The circuit court determined that Ms. Hollabaugh had standing but concluded that

§ 4-304(c) authorized MRO’s fee. The circuit court thus granted MRO’s motion to dismiss.

The Appellate Court of Maryland affirmed on both issues. Hollabaugh v. MRO

Corp., No. 1049, Sept. Term, 2023, 2024 WL 2858350, at *1 (Md. App. June 6, 2024).

The court held that Ms. Hollabaugh had standing, id. at *3-4, but it determined that

§ 4-304(c) authorized MRO’s search fee, id. at *10. Although the court concluded that

both parties proposed facially reasonable interpretations of the statute, it determined that

Ms. Hollabaugh’s reading was inconsistent with the statute’s stated “purpose” to permit

providers to charge a “reasonable cost-based fee” for record retrieval and preparation. Id.

at *5-10.

We granted Ms. Hollabaugh’s petition for a writ of certiorari to decide whether the

Confidentiality Act authorizes MRO’s search fee, and we granted MRO’s cross-petition on

the issue of whether Ms. Hollabaugh has standing to raise that claim.

STANDARD OF REVIEW

This Court reviews without deference the grant of a motion to dismiss for failure to

state a claim. Elsberry v. Stanley Martin Cos., LLC, 482 Md. 159, 178 (2022). In its

review, the Court “must assume the truth of, and view in a light most favorable to the non-

moving party, all well-pleaded facts and allegations contained in the complaint, as well as

all inferences that may reasonably be drawn from them[.]” RRC Northeast, LLC v. BAA

Maryland, Inc., 413 Md. 638, 643 (2010).

3 DISCUSSION

I. STATUTORY BACKGROUND

The Confidentiality Act seeks to protect the privacy of patients and ensure the

accuracy and confidentiality of medical records by establishing “clear and certain rules”

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