Comm'r of Mental Health & Addiction Services v. Freedom of Information Comm'n
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The Supreme Court reversed in part the judgment of the trial court ordering the disclosure of a redacted version of a police report created by the police department at the Whiting Forensic Division of Connecticut Valley Hospital documenting the police department's investigation into the death of a Whiting patient after a medical event, holding that the report, with minimal redaction, must be disclosed pursuant to the Freedom of Information Act (FOIA), Conn. Gen. Stat. 1-200 et seq.
After the trial court ordered the disclosure of a redacted version of the police report the Freedom of Information Commission appealed, arguing that the report should be released in its entirety under FOIA because it was not exempt for disclosure by the psychiatrist-patient communications privilege set forth in Conn. Gen. Stat. 52-146d(2) and 52-146e(a), as well as the Health Insurance Portability and Accountability Act (HIPAA), 42 U.S.C. 1320d et seq., as implemented by the Privacy Rule, 45 C.F.R. 160.101 et seq. The Supreme Court reversed, holding (1) the police report was not a communication or record exempt from disclosure under FOIA; and (2) because the report included identifiable patient information, the report should be redacted in the manner described in this opinion.
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