Pacific Radiation Oncology v. Queen's Med. Ctr., No. 14-17050 (9th Cir. 2015)Annotate this Case
PRO filed suit against QMC, alleging that QMC's adoption of a closed-facility model was a pretext to prevent PRO physicians from competing with QMC. PRO sought injunctive relief against QMC, arguing that QMC's review and use of patient records violated the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 42 U.S.C. 1320d, and the Hawaii Constitution. The district court denied the injunction. In light of Devose v. Herrington, the court held that there must be a relationship between the injury claimed in the motion for injunctive relief and the conduct asserted in the underlying complaint. This requires a sufficient nexus between the claims raised in a motion for injunctive relief and the claims set forth in the underlying complaint itself. In this case, PRO’s motion for injunctive relief does not have a relationship or nexus to the underlying complaint. Therefore, the court concluded that the district court properly refused to grant the relief requested. Accordingly, the court affirmed the judgment.