Jennifer Hall v. Highlands Hospital Corporation

CourtCourt of Appeals of Kentucky
DecidedOctober 13, 2022
Docket2021 CA 000242
StatusUnknown

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

Bluebook
Jennifer Hall v. Highlands Hospital Corporation, (Ky. Ct. App. 2022).

Opinion

RENDERED: OCTOBER 14, 2022; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2021-CA-0242-MR

JENNIFER HALL APPELLANT

APPEAL FROM FLOYD CIRCUIT COURT v. HONORABLE JOHNNY RAY HARRIS, JUDGE ACTION NO. 19-CI-00505

HIGHLANDS HOSPITAL CORPORATION AND CONSOLIDATED HEALTH SYSTEMS, INC. APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CLAYTON, CHIEF JUDGE; ACREE AND TAYLOR, JUDGES.

ACREE, JUDGE: Appellant Jennifer Hall appeals the Floyd Circuit Court’s

October 21, 2020 order granting summary judgment in favor of Appellees

Highlands Hospital Corporation and Consolidated Health Systems. We affirm. BACKGROUND

From October 2017 until January 29, 2019, Appellant worked at an

after-hours clinic operated by Appellees. When Appellees determined Appellant

breached patient confidentiality, they terminated her employment.

Appellant worked as a medical assistant, which involved assisting

healthcare providers at the clinic. Immediately after being hired, Appellant

received extensive training concerning the confidentiality of the clinic’s patients

and the importance of protecting patient confidentiality. Appellees fired Appellant

over two instances in which Appellant revealed patient confidential information.

The first incident occurred on January 10, 2019, when Appellant

commented on a Facebook post concerning the death of a patient. She posted:

“Please be in prayer for the family of one of my sweet patients[.]” By doing so,

Appellant revealed the deceased had been a patient, which constituted revealing

confidential information in violation of Appellee’s policies. We agree with the

circuit court that this violation likely did not amount to a material violation of

Appellee’s policies we discuss below.

The second, and more serious violation, occurred on January 14,

2019, when a female patient presented to the clinic with a spot on the back of her

thigh. A doctor looked at the mark and treated the patient for, what the doctor

believed, was a chemical burn. Appellant believed the doctor misdiagnosed the

-2- patient and took a picture of the mark with her personal cellphone. Both parties

dispute whether Appellant had permission to take the photo, but whether she had

permission is irrelevant to our analysis.

After taking the photo, Appellant began showing the photo to her co-

workers (nine in total, eight which were not directly involved in the patient’s care),

believing the doctor misdiagnosed the mark. After showing another doctor the

photo, the second doctor re-diagnosed the mark, confirming Appellant’s suspicion.

However, when the patient learned of Appellant’s conduct, she reported Appellant

to Appellees.

Initially, Appellees suspended Appellant without pay while it

investigated Appellant’s actions. After this investigation, Appellees terminated

Appellant for violations of numerous policies maintained by Appellees.

Appellees required Appellant (and all employees) annually to review

and sign the Highlands Health System Employee Confidentiality Agreement,

which states: “I will not intentionally share or release confidential information

about the patient to anyone not directly involved in the patient’s care[.]” Under

this policy, patient information may only be shared with individuals directly

involved with the patient’s care. Co-workers not directly involved in the patient’s

care should not be told confidential information about a patient.

-3- Additionally, Appellees have a Wireless Communication Devices

Policy, which prohibits the use of personal cellphones in patient treatment areas to

take photographs. Appellees also maintain a Confidential Matters Policy, which

states: “[r]easons for admission and information about diagnosis and treatment are

absolutely confidential and must be respected as such[.]” Appellee also has a

Social Media Policy, which prohibits employees from sharing information about

patients, including a patient’s identity, on social media.

Additionally, as the circuit court noted, Appellant was trained (as all

employees are) “how to report a concern regarding patient safety or care issues[.]”

(Record (R.) at 558).

In August 2019, Appellant filed suit against Appellees alleging they

violated KRS1 216B.165(3), which prohibits employers from retaliating against

employees who makes reports regarding their reasons for “believ[ing] that the

quality of care of a [healthcare] patient . . . is in jeopardy[.]” KRS 216B.165(1),

(3). Appellant alleges her actions fall under the protection of that statute. She also

later amended her complaint to include a defamation claim.

Appellee filed a motion for summary judgment, and the circuit court

granted the motion as to all claims.

This appeal follows.

1 Kentucky Revised Statutes.

-4- STANDARD OF REVIEW

A circuit court properly grants summary judgment “if the pleadings,

depositions, answers to interrogatories, stipulations, and admissions on file,

together with the affidavits, if any, show that there is no genuine issue as to any

material fact and that the moving party is entitled to a judgment as a matter of

law.” CR2 56.03. “An appellate court’s role in reviewing a summary judgment is

to determine whether the trial court erred in finding no genuine issue of material

fact exist[ed] and the moving party was entitled to judgment as a matter of law.”

Feltner v. PJ Operations, LLC, 568 S.W.3d 1, 3 (Ky. App. 2018).

Thus, appellate courts use de novo review when reviewing a circuit

court’s order granting summary judgment. Cmty. Fin. Servs. Bank v. Stamper, 586

S.W.3d 737, 741 (Ky. 2019). However, summary judgment “is only proper where

the movant shows that the adverse party could not prevail under any

circumstances.” Steelvest, Inc. v. Scansteel Serv. Ctr., Inc., 807 S.W.2d 476, 480

(Ky. 1991).

ANALYSIS

The statute governing Appellant’s retaliatory discharge claim states,

in full, as follows:

(1) Any agent or employee of a health care facility or service licensed under this chapter who knows or has

2 Kentucky Rules of Civil Procedure.

-5- reasonable cause to believe that the quality of care of a patient, patient safety, or the health care facility’s or service’s safety is in jeopardy shall make an oral or written report of the problem to the health care facility or service, and may make it to any appropriate private, public, state, or federal agency.

(2) Any individual in an administrative or supervisory capacity at the health care facility or service who receives a report under subsection (1) of this section shall investigate the problem, take appropriate action, and provide a response to the individual reporting the problem within seven (7) working days.

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Related

Kentucky Department of Corrections v. McCullough
123 S.W.3d 130 (Kentucky Supreme Court, 2004)
Steelvest, Inc. v. Scansteel Service Center, Inc.
807 S.W.2d 476 (Kentucky Supreme Court, 1991)
Columbia Sussex Corp., Inc. v. Hay
627 S.W.2d 270 (Court of Appeals of Kentucky, 1981)
Colorama, Inc. v. Johnson
295 S.W.3d 148 (Court of Appeals of Kentucky, 2009)
Feltner v. PJ Operations, LLC
568 S.W.3d 1 (Court of Appeals of Kentucky, 2018)

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