John Doe v. Medlantic Health Care Group, Inc., 814 A.2d 939 (D.C. 2003)

In this decision, the District of Columbia Court of Appeals reversed the trial court’s decision and remanded the case with instructions for judgment to be entered in favor of John Doe, the plaintiff-appellant. In 1996, Doe, who has HIV, was working two jobs: by day, he worked for a federal agency and at night as a janitor for a company that contracted to clean the Department of State. One of his co-workers at his night job, Tijuana Goldring, also worked at the Washington Hospital Center (WHC). Doe went to WHC for medical treatment, where he paid a courtesy call to Goldring. Following this encounter, Goldring accessed Doe’s confidential patient information and told their co-workers that he had HIV. Doe filed a complaint against Medlantic Health Care Group, Inc. (Medlantic), alleging, among other things, breach of confidential relationship based on WHC’s negligence in allowing Goldring access to confidential patient information. The Court of Appeals found that although WHC’s protocols to safeguard medical records were not in themselves deficient, the evidence that there were significant lapses in enforcement and that Goldring was the source of the unauthorized disclosure was enough for the jury to have concluded that WHC “breached its duty as a fiduciary to maintain the confidentiality of Doe’s medical records.”