John Doe Vs. Central Iowa Health System D/b/a Iowa Health Des Moines D/b/a Iowa Methodist Medical Center And D/b/a Iowa Lutheran Hospital

CourtSupreme Court of Iowa
DecidedMay 15, 2009
Docket07–1017
StatusPublished

This text of John Doe Vs. Central Iowa Health System D/b/a Iowa Health Des Moines D/b/a Iowa Methodist Medical Center And D/b/a Iowa Lutheran Hospital (John Doe Vs. Central Iowa Health System D/b/a Iowa Health Des Moines D/b/a Iowa Methodist Medical Center And D/b/a Iowa Lutheran Hospital) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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John Doe Vs. Central Iowa Health System D/b/a Iowa Health Des Moines D/b/a Iowa Methodist Medical Center And D/b/a Iowa Lutheran Hospital, (iowa 2009).

Opinion

IN THE SUPREME COURT OF IOWA No. 07–1017

Filed May 15, 2009

JOHN DOE,

Appellant,

vs.

CENTRAL IOWA HEALTH SYSTEM d/b/a IOWA HEALTH DES MOINES d/b/a IOWA METHODIST MEDICAL CENTER and d/b/a IOWA LUTHERAN HOSPITAL,

Appellees.

Appeal from the Iowa District Court for Polk County, Douglas F.

Staskal, Judge.

The plaintiff appeals a district court decision granting defendants’

motion for judgment notwithstanding the verdict, setting aside the jury

verdict, and dismissing plaintiff’s petition. AFFIRMED.

Gretchen R. Jensen and Jeffrey L. Goodman of Goodman &

Associates, P.C., West Des Moines, for appellant.

Frank B. Harty, Thomas W. Foley, and Hannah M. Rogers of

Nyemaster, Goode, West, Hansell & O’Brien, P.C., Des Moines, for

appellees. 2

WIGGINS, Justice.

In this appeal, we must decide whether the district court was

correct when it granted the defendants’ motion for judgment

notwithstanding the verdict. Because the plaintiff failed to produce

sufficient evidence to support his claim that the disclosures of his mental

health records were the cause of his emotional distress, we affirm the

judgment of the district court.

I. Prior Proceedings.

John Doe, an employee of Central Iowa Health System, brought an

action against Central Iowa Health System, Iowa Health System, Iowa

Methodist Medical Center, and Iowa Lutheran Hospital1 alleging that in

2003 they unlawfully disclosed his medical and/or mental health

information to Doe’s coemployees. Doe alleged Iowa Health violated the

privacy rules of the Federal Health Insurance Portability and

Accountability Act, breached its fiduciary duty, and violated the privacy

rules of Iowa Code chapter 228 covering the disclosure of mental health

and psychological information. Doe further alleged these violations

caused him to suffer humiliation, embarrassment, mental anguish, fear

of social ostracism, fear regarding job security, and other severe

emotional distress.

The case proceeded to trial on the alleged violation of chapter 228.

The Code provides in relevant part:

1. Except as specifically authorized in section 228.3, 228.5, 228.6, 228.7, or 228.8, a mental health professional, data collector, or employee or agent of a mental health professional, of a data collector, or of or for a mental health facility shall not disclose or permit the disclosure of mental health information.

1These defendants will be collectively referred to as “Iowa Health.” 3

2. Upon disclosure of mental health information pursuant to section 228.3, 228.5, 228.6, 228.7, or 228.8, the person disclosing the mental health information shall enter a notation on and maintain the notation with the individual’s record of mental health information, stating the date of the disclosure and the name of the recipient of mental health information.

The person disclosing the mental health information shall give the recipient of the information a statement which informs the recipient that disclosures may only be made pursuant to the written authorization of an individual or an individual’s legal representative, or as otherwise provided in this chapter, that the unauthorized disclosure of mental health information is unlawful, and that civil damages and criminal penalties may be applicable to the unauthorized disclosure of mental health information.

3. A recipient of mental health information shall not disclose the information received, except as specifically authorized for initial disclosure in section 228.3, 228.5, 228.6, 228.7, or 228.8. However, mental health information may be transferred at any time to another facility, physician, or mental health professional in cases of a medical emergency or if the individual or the individual’s legal representative requests the transfer in writing for the purposes of receipt of medical or mental health professional services, at which time the requirements of subsection 2 shall be followed.

Iowa Code § 228.2 (2003).

At the close of Doe’s case, Iowa Health moved for a directed verdict.

In their motion for a directed verdict they made the following claims:

(1) Iowa Code chapter 228 does not provide Doe with a private cause of

action; (2) if chapter 228 does provide a private cause of action, Iowa

Health did not violate chapter 228 because any disclosures made were

not in violation of chapter 228; (3) any disclosures made by Iowa Health

employees was done outside the scope of their employment; (4) Doe failed

to present substantial evidence that he suffered any emotional distress

caused by the actions of Iowa Health employees.

The court overruled the motion for a directed verdict. In doing so,

the court stated it believed chapter 228 created a private cause of action 4

for emotional distress without a showing of physical injury or a showing

of outrageous conduct. However, the court did state that in its mind

“there is a huge issue in this case about the sufficiency of the evidence to

prove emotional distress.” The court reserved ruling on the sufficiency of

the evidence issue.

At the close of all the evidence, Iowa Health renewed its motion for

directed verdict. The court renewed the ruling it made at the end of

Doe’s evidence and decided to submit the case to the jury. The court

used the following marshalling instruction to instruct the jury on the

elements Doe had to prove to recover under a private cause of action

under section 228.2.

INSTRUCTION NO. 12

In order to recover on his claim of unlawful disclosure of mental health information the Plaintiff must prove all of the following propositions:

1. That an employee of the Defendant disclosed the Plaintiff’s mental health information. The term “disclosed” is defined in Instruction No. 13. The term “mental health information” is defined in Instruction No. 13.

2. That the employee who disclosed the Plaintiff’s mental health information did so:

a. within the scope of his or her employment. The phrase “within the scope of employment” is defined in Instruction No. 14; or

b. with the authorization of a managerial employee of the Defendant.

3. The disclosure was unlawful. The term “unlawful” is defined in Instruction No. 15.

4. That the unlawful disclosure was the proximate cause of emotional distress to the Plaintiff. The term “emotional distress” is defined in Instruction No. 16. 5

5. The amount of damage.

If the Plaintiff has failed to prove any of these propositions, the Plaintiff is not entitled to recover damages. If the Plaintiff has proved all of these propositions, he is entitled to recover some amount of damages as explained in Instruction No. 17.

The court further instructed the jury that the only element of damages

upon which the jury could return a verdict was for Doe’s emotional

distress.

The jury found Doe proved all the elements as required by the

marshalling instruction and returned a verdict in favor of Doe for

$175,000. Iowa Health then filed a motion for judgment notwithstanding

the verdict or in the alternative a motion for new trial or remittitur. Iowa

Health raised the same issues as it raised in its motion for directed

verdict. The district court sustained Iowa Health’s motion for judgment

notwithstanding the verdict claiming the disclosures by four of Iowa

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John Doe Vs. Central Iowa Health System D/b/a Iowa Health Des Moines D/b/a Iowa Methodist Medical Center And D/b/a Iowa Lutheran Hospital, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-doe-vs-central-iowa-health-system-dba-iowa-health-des-moines-dba-iowa-2009.