Amrhein v. eClinical Works, LLC, No. 19-1429 (1st Cir. 2020)Annotate this Case
The First Circuit affirmed the judgment of the district court finding that Plaintiffs, patients whose healthcare providers used eClinicalWorks, LLC (ECW) software to record and store their medical records, lacked standing to bring this case, holding that, without further injury, Plaintiffs lacked standing to bring this case.
Plaintiffs were the estates of two deceased patients whose medical records were kept and stored by healthcare providers using ECW. Plaintiffs alleged that ECW's system was riddled with bugs that showed healthcare providers false and incomplete data about patients' medical problems and treatments and that ECW hid the glitches from government regulators. Plaintiffs brought several state common-law claims and sought to represent a class of millions of other similarly-situated patients. The district court dismissed the case under Fed. R. Civ. P. 12(b)(1). The First Circuit affirmed, holding that the arguments as presented sought redress based on a moot risk of misdiagnosis or mistreatment that no statute or common-law claim makes suable. Therefore, Plaintiffs lacked standing to bring this case.