Jacqmin v. Savilinx

CourtSuperior Court of Maine
DecidedSeptember 20, 2022
DocketCUMbcd-cv-21-37
StatusUnpublished

This text of Jacqmin v. Savilinx (Jacqmin v. Savilinx) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jacqmin v. Savilinx, (Me. Super. Ct. 2022).

Opinion

STATE OF MAINE BUSINESS AND CONSUMER COURT CUMBERLAND, ss. CIVIL ACTION DOCKET NO. BCD-CIV-2021-00037

SCOTT JACQMIN, ) ) Plaintiff, ) ) ) v. ) ORDER GRANTING MOTION ) FOR SUMMARY JUDGMENT ) IN FAVOR OF DEFENDANT ) SAVILINX SAVILINX, ) ) Defendant. )

INTRODUCTION

This case is about a dispute underlying an employee’s termination. Plaintiff Scott Jacqmin

(“Jacqmin”) brings claims for violation of Maine’s Whistleblower Protection Act, 26 M.R.S.A. §

831 et seq. (“Count I”), and for invasion of privacy (“Count II”). At present before the Court is

Defendant SaviLinx’s (“SaviLinx”) Motion for Summary Judgment under Maine Rule of Civil

Procedure 56(b) as to each claim. For the reasons discussed below, the Court GRANTS summary

judgment to SaviLinx on Counts I and II.

STANDARD OF REVIEW

Summary judgment is appropriate when the parties’ statements of material facts and the

portions of the record referenced therein “disclose no genuine issues of material fact and reveal

that one party is entitled to judgment as a matter of law.” Currie v. Indus. Sec., Inc., 2007 ME 12,

¶ 11, 915 A.2d 400 (citing M.R. Civ. P. 56(c)). “A material fact is one that can affect the outcome

of the case, and there is a genuine issue when there is sufficient evidence for a fact finder to choose

between competing versions of the fact.” Lougee Conservancy v. CitiMortgage, Inc., 2012 ME

1 103, ¶ 11, 48 A.3d 774 (quoting Stewart-Dore v. Webber Hosp. Ass'n, 2011 ME 26, ¶ 8, 13 A.3d

773). The Court must view the parties’ statements of material facts in the light most favorable to

the non-movant and must draw all reasonable inferences in favor of the same. See Levis v.

Konitzky, 2016 ME 167, ¶ 19, 151 A.3d 20.

To withstand a motion for a summary judgment, the plaintiff must establish “a prima facie

case for each element of [their] cause of action[, but if] a plaintiff does not present sufficient

evidence on the essential elements [then] the defendant is entitled to a summary judgment.” Watt

v. UniFirst Corp., 2009 ME 47, ¶ 21, 969 A.2d 897 (citations omitted). That is, a defendant is

entitled to summary judgment when “the plaintiff presents insufficient evidence on an essential

element in [their] cause of action, such that ‘the defendant would . . . be entitled to judgment as a

matter of law on that state of the evidence at trial.’” Doyle v. Dep’t of Hum. Servs., 2003 ME 61,

¶ 9, 824 A.2d 48 (quoting Johnson v. Carleton, 2001 ME 12, ¶ 11, 765 A.2d 571).

FACTS

For the limited purpose of deciding SaviLinx’s Motion for Summary Judgment, this Court

finds the following material facts 1 undisputed:

SaviLinx is a Maine business entity with a primary place of business in Brunswick, Maine.

(Pl.’s Compl. ¶ 3.) Jacqmin was employed by SaviLinx beginning during 2015 and through May

10, 2019. (Pl.’s Compl. ¶ 6; Supp.’g S.M.F. ¶ 1.) On or about September 30, 2015, as part of

SaviLinx’s hiring process Jacqmin signed a Photo Release Form permitting SaviLinx “its

representatives and employees the right to take photographs” of him, and which authorized

1 “Documents that are unaccompanied by an authenticating affidavit based on personal knowledge under Maine Rule of Civil Procedure 56(e) should not be considered for purposes of summary judgment.” Emery Lee & Sons, Inc. v. Acadia Ins. Grp., LLC, 2016 WL 1706499, *5 (citing Cach LLC v. Kulas, 2011 ME 70, ¶ 11, 21 A.3d 1015). Accordingly, the Court has disregarded any such documents. The Court has also disregarded any statement of fact not properly supported by a specific record citation. M.R. Civ. P. 56(h)(4).

2 SaviLinx and “its assigns and transferees to copyright, use and publish the [photographs] in print

and/or electronically.” (Supp.’g S.M.F. ¶ 2; Jacqmin Dep. Ex. 3.4.) Further, the release form

permitted SaviLinx to use photographs of Jacqmin taken in accordance therewith “with or without

[Jacqmin’s] name for any lawful purpose, including . . . as publicity, illustration, advertising and

Web content.” (Supp.’g S.M.F. ¶ 2; Jacqmin Dep. Ex. 3.4.)

As part of Jacqmin’s job for SaviLinx, he provided information by telephone to participants

in a federal employee benefits program known as “FEDVIP.” (Supp.’g S.M.F. ¶ 3.) To perform

this aspect of his job, Jacqmin was provided access to private information belonging to FEDVIP

participants. (Supp.’g S.M.F. ¶ 4.) Jacqmin’s job also entailed maintenance of the confidentiality

of FEDVIP participants’ private healthcare information in accordance with the Health Insurance

Privacy and Accountability Act of 1996 (“HIPAA”), and designation of client data as “Protected

Healthcare Information” (“PHI”) within the meaning of HIPAA. 2 (Opp. S.M.F. ¶ 3). Jacqmin

received training from SaviLinx, at the outset of his employment and annually, on the application

of HIPAA to his job duties, and he could distinguish confidential PHI from non-PHI. (Supp.’g

S.M.F. ¶¶ 7, 9-11.) SaviLinx’s training program mandated that Jacqmin and other employees of

2 “‘PHI’ is any individually identifiable health information relating to the . . . health condition of [an] individual regardless of the form in which it is maintained.” (Jacqmin Dep. Ex. 20, 1.) “A name or social security number by itself is not considered PHI. But combine that information with something related to that person’s health, and it becomes PHI.” (Id.) HIPAA is breached when PHI is improperly used or disclosed. (Id. at 3.) According to the federal rules, “Breach” means impermissible “acquisition, access, use, or disclosure of [PHI] . . . which compromises the security or privacy” thereof. 45 C.F.R. § 164.402 (2013) (emphasis added). Excluded from the definition of “breach” within the meaning of HIPAA is “disclosure of [PHI] where a covered entity or business associate has a good faith belief that an unauthorized person to whom the disclosure was made would not reasonably have been able to retain such information.” Id. § 164.402(1)(iii). Implicitly, this exclusion need not be applied when the unauthorized person to whom the disclosure was made could not first obtain the PHI. “Unsecured” PHI is PHI that is “not rendered unusable, unreadable, or indecipherable to unauthorized persons” through the use of technology or methodology specified by the Guidance to Render Unsecured Protected Health Information Unusable, Unreadable or Indecipherable to Unauthorized Individuals, 74 Fed. Reg. 42,740, 42,742 (Aug. 24, 2009). 45 C.F.R. § 164.402. PHI detailed in paper, film, or other hard copy media are secured or protected when the media is shredded or destroyed “such that the PHI cannot be read or otherwise cannot be reconstructed.” Guidance to Render Unsecured Protected Health Information Unusable, Unreadable or Indecipherable to Unauthorized Individuals, 74 Fed. Reg. 42,740, 42,742-743 (Aug. 24, 2009) (codified in part at 45 C.F.R. § 164.402).

3 SaviLinx, when a HIPAA breach occurred, “quickly investigate the breach, mitigate it, document

it, and then notify the covered entity whose information was affected as well as potentially the

Office of Civil Rights at the Department of Health and Human Services.” (Jacqmin Dep. Ex. 20,

3.)

While employed by SaviLinx, Jacqmin was provided a workstation with two computer

monitors. (Supp.’g S.M.F.

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