Doe v. North Greenville Hospital

Cureton, Judge;

Appellant, John Doe,1 sought to recover actual and punitive damages against respondent, North Greenville Hospital, based on an alleged improper release of his medical records to the insurance company providing his hospitalization coverage who, in turn, forwarded the records to his wife. In his complaint, Doe alleged two causes of action. First, for the negligent violation of federal regulations found at 42 C.F.R., Part 2, and second, for public disclosure of a private fact. The hospital’s answer admitted that medical records generated during Doe’s hospitalization had been…