Jo Ellen Smith Psychiatric Hospital v. Harrell

COVINGTON, Chief Judge.

This case involves the inadvertent release of insurance payment records to the parents of a former patient of Jo Ellen Smith Psychiatric Hospital, the plaintiff. These records, sometimes referred to as “Blue Cross Provider Registers,” or “registers,” contained the last name, beginning initial of the first name1 and social security number of 39 patients at the Psychiatric Hospital, who were Blue Cross insureds. These registers document payment by Blue Cross to the hospital, a psychiatric, drug and alcohol treatment facility, for services the hospital rendered to the…