Procedural Posture

Appellant former employee sought review of the judgments of the Superior Court of Alemeda County (California), which dismissed appellant’s respective claims against appellees, psychiatrists and former employer, for the unauthorized release of medical information in violation of the Confidentiality of Medical Information Act, Cal. Civ. Code § 56 et seq., and the privacy clause of Cal. Const. art. I, §1.

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Overview

Appellant former employee sought to take time off from work for a disabling stress-related condition. Appellee employer referred appellant for medical evaluation under its short-term disability policy. Appellant was evaluated by appellee psychiatrists, who made detailed reports to appellee employer, including statements that appellant’s condition might be linked to an alcohol abuse problem. Appellee employer terminated appellant when he refused to enter an alcohol residential treatment program as a condition for continued employment, although there was no evidence that he was an alcoholic. Appellant filed lawsuits against appellees for violating the Confidentiality of Medical Information Act (Act), Cal. Civ. Code § 56 et seq., and for violating his right of privacy under Cal. Const. art. I, § 1. The trial court dismissed the suit. On appeal, the court reversed, holding that under the Act, medical information compiled during appellant’s psychiatric examination could not be disclosed without his authorization or consent and could not be used against him. The court held that the release of information and appellant’s discharge violated his state constitutional right to privacy.

Outcome

The court reversed the dismissal of appellant former employee’s claims against appellees, former employer and psychiatrists, because the release of medical information compiled during a psychiatric examination of appellant without his authorization or consent violated the Confidentiality of Medical Information Act, and that release and his subsequent discharge violated his state constitutional right to privacy.