French v. Marion Gen. Hosp. (In re Patterson)
Jun
03
2008
Ruling
Postpetition disclosure of debtor's medical billing records by creditor did not give rise to a cause of action on behalf of the estate.
Procedural posture
Plaintiff trustee brought an action asserting injury on behalf of debtors against defendant creditor, who placed debtors' medical billing records in the public domain. The trustee brought three causes of action: (1) breach of confidence; (2) invasion of privacy; and (3) a violation of the Health Insurance Portability and Accountability Act,.42 U.S.C.S. § 1320d. The creditor moved to dismiss pursuant to Fed. R. Bankr. P. 7012(b)(6).
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Court
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