Wiese v. Riverton Memorial Hospital, LLC
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The Supreme Court reversed the order of district court granting summary judgment to Riverton Memorial Hospital, LLC and dismissing this complaint alleging that Hospital violated the now-repealed Wyoming Hospital Records and Information Act, Wyo. Stat. Ann. 35-2-605 to 35-2-617, holding that a genuine issue of material fact existed precluding summary judgment.
In their complaint, Rebecca and Tyler Wiese claimed that the Hospital failed to provide them all "health care information" concerning Rebecca's labor and delivery, including information associated with her Centricity Perinatal electronic medical record, in violation of the Act. The district court granted summary judgment of the Hospital, concluding that the Hospital complied with the Act by informing the Wieses and that Centricity electronic record and audit trial did not exist and/or could not be found. The Supreme Court reversed, holding (1) audit trails were "health care information" under the Act; and (2) a genuine issue of material fact existed as to whether Hospital complied with the Act with respect to Rebecca's Centricity electronic record and audit trail.
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