Z.D. v. Community Health Network, Inc.
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The Supreme Court affirmed in part and reversed in part the order of the trial court granting summary judgment in favor of Plaintiff on her claims against Defendant, a hospital who mailed a letter containing Plaintiff's private health matter to a third party who posted the letter to social media, holding that genuine issues of material fact remained.
Plaintiff filed suit against a hospital alleging that it invaded her privacy by publicly disclosing her private information and negligently failed to maintain the confidentiality of her information. The trial court granted summary judgment for the hospital. The Supreme Court reversed in part, holding (1) Defendant was not entitled to summary judgment on Plaintiff's privacy claim because the hospital did not negate the public-disclosure tort's publicity element; (2) Defendant was entitled to partial summary judgment on Plaintiff's negligence claim; and (3) genuine issues of material fact remained as to whether Plaintiff's pecuniary damages were recoverable and whether Defendant was the proximate cause of those damages.
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