VEST MONROE, LLC v. DOE

906 S.E.2d 406, 319 Ga. 649
CourtSupreme Court of Georgia
DecidedSeptember 4, 2024
DocketS23G1224
StatusPublished

This text of 906 S.E.2d 406 (VEST MONROE, LLC v. DOE) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
VEST MONROE, LLC v. DOE, 906 S.E.2d 406, 319 Ga. 649 (Ga. 2024).

Opinion

319 Ga. 649 FINAL COPY

S23G1224. VEST MONROE, LLC et al. v. DOE.

BETHEL, Justice.

When faced with resolving the question of whether class

certification is appropriate, a trial court enjoys broad discretion. See

Carnett’s, Inc. v. Hammond, 279 Ga. 125, 127 (3) (610 SE2d 529)

(2005). OCGA § 9-11-23 guides the court’s exercise of that discretion

and sets forth the requirements a plaintiff must meet in order to

represent a class. Among other requirements, a plaintiff must show

that “[t]here are questions of law or fact common to the class” and

that his own claims are “typical of the claims . . . of the class,”

otherwise known as the commonality and typicality requirements.

See OCGA § 9-11-23 (a) (2), (3). In accordance with the broad

discretion afforded the trial court in deciding whether a plaintiff has

met the statutory requirements, an appellate court’s scope of review

is limited to assessing whether the trial court abused its discretion.

See State Farm Mut. Auto. Ins. Co. v. Mabry, 274 Ga. 498, 499-500 (1) (556 SE2d 114) (2001). In this case, we are tasked with assessing

whether the Court of Appeals properly applied that deferential

standard of review to the trial court’s denial of class certification.

John Doe, the named plaintiff in this putative class action,

received treatment at Ridgeview Institute — Monroe, a behavioral

health and addiction treatment facility. Following the unauthorized

disclosure of his and other patients’ information by a former

Ridgeview employee, Doe sued Ridgeview’s owners and operators

and its chief executive officer (collectively, “Vest Monroe”), not only

seeking to recover monetary damages caused by the unauthorized

disclosure of his own patient information, but also proposing to seek

relief for a class of other affected patients.1 The trial court denied

Doe’s motion for class certification, finding that Doe failed to

establish either the required elements of commonality or typicality

1 Doe alleges 11 different claims: breach of express contract, breach of

implied contract, unjust enrichment, negligence, negligence per se, negligent misrepresentation, invasion of medical privacy, common law invasion of privacy, breach of confidentiality/confidential relations, wrongful disclosure of privileged information, and violation of Georgia’s Uniform Deceptive Trade Practices Act, OCGA § 10-1-370 et seq. 2 under OCGA § 9-11-23 (a). Doe appealed,2 and the Court of Appeals

reversed the trial court’s decision, see Doe v. Vest Monroe, 368 Ga.

App. 572 (890 SE2d 439) (2023), although one member of the panel

dissented, see id. at 579-580 (Brown, J., dissenting). We granted

certiorari to consider whether the trial court abused its discretion by

finding that the putative class lacked commonality and typicality

under OCGA § 9-11-23 (a). For the reasons explained below, we

conclude that the trial court acted within its discretion in finding a

lack of typicality, so we reverse the judgment of the Court of

Appeals. And because a lack of either typicality or commonality

supports the denial of class certification, we do not address

commonality.

1. The relevant facts and procedural history of this case are as

follows. The unauthorized disclosure of patient information giving

rise to this case is attributed to the actions of Rhonda Rithmire, a

2 See OCGA § 9-11-23 (g) (“A court’s order certifying a class or refusing

to certify a class shall be appealable in the same manner as a final order to the appellate court which would otherwise have jurisdiction over the appeal from a final order in the action.”). 3 former employee at Ridgeview. Rithmire became director of plant

operations at Ridgeview in September 2018. As director, Rithmire

was responsible for managing and organizing the facility’s

operations, including housekeeping, maintenance, and

groundskeeping. While Rithmire’s duties did not involve the direct

delivery of healthcare services, aspects of her job required that she

have access to certain patient information. But during her

employment, Rithmire also allegedly accessed and maintained

possession of a significant volume of more sensitive patient

information of various sorts that was unrelated to her job duties.

Rithmire was terminated from her employment at Ridgeview

in June 2019, and soon after, she contacted plaintiff’s counsel of

record in a medical malpractice case pending against Ridgeview and

later provided the attorney with digital copies of documents she

obtained from Ridgeview, as well as paper documents and audio

recordings.3 Rithmire also provided the documents to her personal

3 The attorney shared some of those documents with experts he had retained in his pending case and provided the entirety of the Ridgeview

4 attorney. After becoming aware of the disclosure of the patient

information, Ridgeview initiated an investigation and ultimately

discovered that information pertaining to nearly 2,000 patients had

been compromised.

In March 2020, Vest Monroe, LLC, filed suit against Rithmire

in federal court. The district court enjoined Rithmire and her

personal counsel from further dissemination of the Ridgeview

documents and ordered her to delete the material in her possession.

Vest Monroe notified all potentially affected individuals of the

incident.

In November 2020, after receiving notice of the incident, Doe

filed a class action complaint against Vest Monroe, asserting a

number of claims related to the unauthorized disclosure of patient

information. Doe moved for class certification in March 2022.4 After

documents to all counsel of record in that case during the course of discovery. The attorney also shared some materials with another plaintiff’s attorney in a separate medical malpractice action against Ridgeview. That attorney’s actions are not at issue in this appeal. 4 Doe sought certification of the following class:

All persons who were adult patients of Ridgeview Institute

5 a hearing, the trial court denied the motion, finding that Doe failed

to establish the required elements of commonality and typicality.

Specifically, in finding a lack of commonality, the court noted

the differences in the type of documents disclosed with respect to

members of the proposed class, in that some contained diagnosis and

treatment information, while others did not. With respect to Doe,

the trial court noted that the information released was contained in

discharge summaries and census reports and that no diagnosis or

treatment information was revealed. The court considered that

Rithmire was authorized to access certain of the information as part

of her job duties. But, the trial court reasoned, other information

contained in sensitive clinical files raised a qualitatively different

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Bluebook (online)
906 S.E.2d 406, 319 Ga. 649, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vest-monroe-llc-v-doe-ga-2024.