Garrett

Appellant Eufaula Garrett seeks to overturn a judgment on a directed verdict in favor of respondent William Young, M.D. Appellant brought a lawsuit against respondent for, among other things, invasion of privacy and violation of the Confidentiality of Medical Information Act (Civ. Code, § 56 et. seq., CMIA). The primary issue presented is whether the trial court properly interpreted section 56.16 of the Civil Code, an exception to the CMIA’s general rule prohibiting disclosure of medical information to outsiders. The court ruled that section 56.16 permits health care providers such as respondent to discuss general medical information about a patient without his or her consent, and that the information disclosed by respondent to appellant’s employer was of a sufficiently nonspecific nature to fit within the exception. The court further ruled that under the evidence presented, appellant could not maintain a nonstatutory action for invasion of privacy. We affirm.

Factual and Procedural Background

The Complaint

The complaint alleged that in March 1999, appellant sought medical treatment from respondent for symptoms she felt were being caused by the conditions at her job,…