Bitner v. Pekin Memorial Hospital

Plaintiffs Christopher and Tara Bitner challenge the trial court’s dismissal of a complaint they filed against defendant Pekin Memorial Hospital (Pekin Memorial or the hospital) under the AIDS Confidentiality Act (Act) (410 ILCS 305/1 et seq. (West 1998)). We affirm and hold that the Act does not create a cause of action for a law enforcement officer who seeks disclosure of a suspect’s human immunodeficiency virus (HIV) test results.

Christopher Bitner is a City of Pekin police officer. On January 24, 1999, during the course of an arrest, he was involved in a fracas in which both he and a…