United States v. Huping Zhou

OPINION

M. SMITH, Circuit Judge:

Defendant-Appellant Huping Zhou, a former research assistant at the University of California at Los Angeles Health System (UHS), accessed patient records without authorization after his employment was terminated. In an information, the government charged him with violating the Health Insurance Portability and Accountability Act of 1996 (HIPAA), which imposes a misdemeanor penalty on “[a] person who knowingly and in violation of this part ... obtains individually identifiable health information relating to an individual^]” 42 U.S.C. § 1320d-6(a)(2) (emphasis…