Michael Coto v. Trustees of Bridges of Hope Charitable Trust

CourtCourt of Appeals of Georgia
DecidedMarch 13, 2020
DocketA19A2159
StatusPublished

This text of Michael Coto v. Trustees of Bridges of Hope Charitable Trust (Michael Coto v. Trustees of Bridges of Hope Charitable Trust) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Coto v. Trustees of Bridges of Hope Charitable Trust, (Ga. Ct. App. 2020).

Opinion

SECOND DIVISION MILLER, P. J., RICKMAN and COOMER, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

March 12, 2020

In the Court of Appeals of Georgia A19A2159. COTO et al. v. TRUSTEES OF BRIDGES OF HOPE CHARITABLE TRUST et al.

COOMER, Judge.

In this wrongful death appeal, Michael A. Coto, individually, and Tammy Coto,

individually and as the executor of the estate of Michael C. Coto, (“Appellants”)

challenge the trial court’s denial of their motion to authorize the substance abuse

treatment facility where their son, Michael C. Coto, died to disclose confidential

information concerning certain residents of the facility. Appellants argue that the trial

court erred by denying their motion (i) on the basis that good cause had not been

shown for the disclosures, (ii) on the basis that they failed to give notice to the

patient-residents whose information they were seeking, and (iii) without conducting an in camera review of the records. Because Appellants failed to provide the requisite

notice to the patient-residents, we affirm.

The record shows that in February 2016, Michael C. Coto was admitted to a

residential substance abuse treatment facility operated by Bridges of Hope Charitable

Trust (“BOH”). He died at the facility two days later in a room that he shared with at

least one other resident. An autopsy revealed that he died as a result of the toxic

effects of multiple drugs in his system.

The following year, Michael’s parents filed a civil action seeking recovery for

their son’s death. During discovery, counsel for Appellants told opposing counsel he

wanted to depose three non-party witnesses who Appellants believed had been

residents of BOH and interacted with Michael or Appellants before Michael’s death.1

In response, counsel for BOH stated: “With respect to the three residents you want

to depose, we do not represent them and cannot accept a subpoena on their respective

behalf. We also cannot give you contact information willingly because that would fall

1 At oral argument in this Court, counsel clarified that Appellants only had the first name of two people, and both the first and last name of one other individual who they believed were residents of BOH at the time of Michael’s death that they wanted to depose. They conveyed their desire to depose these individuals to opposing counsel identifying them based only on those names.

2 under the restrictions against disclosure at 42 CFR Part 2 and we have no consent to

disclose any information. You will need to obtain an order.”

Appellants then filed a motion to authorize disclosure of protected patient

information. In the motion, Appellants asked the trial court to authorize release of (1)

the residents’ last-known contact information, (2) information concerning those

residents’ treatment, residency, or work at BOH during the period of time while

Michael was a resident there, and (3) information concerning any actions taken, or

statements given, by those residents with respect to Michael’s death at BOH or any

subsequent investigations.2

The trial court denied the motion on the grounds that the plaintiffs had not

shown good cause for the requested disclosures and that no notice of the requests had

been provided to the non-party residents. We subsequently granted Appellants’

discretionary application for appeal.

1. Appellants argue that the trial court erred in denying the disclosure motion

2 At a hearing on the motion, Appellants modified their request and sought such information and documents with respect to all BOH residents known or believed by the BOH to have interacted with Michael or Appellants at any time.

3 on the basis that they failed to provide notice to the patient-residents whose records

they were seeking. Specifically, they argue that because BOH objected to written

discovery and deposition questions that would elicit the names or contact information

of any non-party residents who may have interacted with Appellants and their son,

BOH made it impossible for them to contact the residents themselves. Therefore,

BOH should be estopped from “taking advantage” of the lack of notice to the patient-

residents by Appellants. Appellants also argue that lack of notice is not a proper basis

to deny the motion outright, and we should remand so that notice can be provided.

We disagree with both contentions.

a. Federal law restricts the disclosure of information obtained “in connection with the performance of any program or activity relating to substance abuse education, prevention, training, treatment, rehabilitation or research” conducted by the United States or with federal money. 42 USC § 290dd-2. Disclosure is permitted with patient consent, 42 USC § 290dd-2(b)(1), or “[i]f authorized by an appropriate order of a court of competent jurisdiction granted after application showing good cause therefor, including the need to avert a substantial risk of death or serious bodily harm,” id. § 290dd-2(b)(2)(C).

4 United States ex rel. Chandler v. Cook County, Illinois, 277 F3d 969, 982 (III) (B)

(7th Cir. 2002).3

In order for a court to issue an order authorizing disclosure, 42 CFR § 2.64 (b)

first requires that notice be provided to the patient and the person holding the records

from whom disclosure is sought. It is undisputed here that notice was not provided

to the patients.

Appellants estoppel argument — that BOH essentially prevented them from

complying with the notice requirement by not disclosing the information during

discovery — is misplaced. In the absence of patient consent or a court order, BOH

was prevented by law from disclosing confidential information about their patients.

See 42 CFR § 2.61 (a) (The “purpose [of a disclosure order] is to authorize a

disclosure or use of patient information which would otherwise be prohibited by 42

USC 290dd-2[.]” (emphasis supplied)). Moreover, even with an order, BOH would

not have been required to disclose the information to Appellants. See id. (“Such an

order does not compel disclosure. A subpoena or a similar legal mandate must be

issued in order to compel disclosure.”).

3 Neither party disputes that this federal statutory scheme applies.

5 Because Appellants did not comply with the notice requirement for obtaining

a disclosure order, and BOH was under no obligation to otherwise disclose the

information, the trial court did not err in denying the motion on that basis. See Hicks

v. Talbott Recovery System, Inc., 196 F3d 1226, 1242, n. 32 (II) (B) (11th Cir. 1999)

(“These stringent federal regulations include application for disclosure [along with]

. . . adequate notice to the patient[.]”). See also Foster v. Swinney, 263 Ga. App. 510,

511 (588 SE2d 307) (2003) (“Georgia’s public policy is to maintain the

confidentiality of medical records, including drug treatment records[.]”).

b. Appellants argue that none of the three cases cited by the trial court stand for

the proposition that a lack of notice to patients or residents can be grounds to deny

a disclosure motion outright.

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Related

Hicks v. Talbott Recovery System, Inc.
196 F.3d 1226 (Eleventh Circuit, 1999)
Foster v. Swinney
588 S.E.2d 307 (Court of Appeals of Georgia, 2003)
McMakin v. Bruce Hospital System
455 S.E.2d 693 (Supreme Court of South Carolina, 1995)

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