Eisenhower Medical Center v. Superior Court

Petitioner Eisenhower Medical Center (EMC) seeks writ review of an order denying its motion for summary adjudication of a cause of action under the Confidentiality of Medical Information Act (CMIA). (Civ. Code, § 56 et seq.) We grant EMC’s petition, concluding that a health care provider cannot be held liable under the relevant portions of the CMIA for the release of an individual’s personal identifying information that is not coupled with that individual’s medical history, mental or physical condition, or treatment.

FACTUAL AND PROCEDURAL BACKGROUND

A computer was stolen from EMC on March 11, 2011, containing an index of over 500,000 persons to whom EMC had assigned a clerical record number dating back to the 1980’s. The information included each person’s name, medical record number (MRN), age, date of birth, and last four digits of the person’s Social Security number (SSN). This information on the computer was password protected but not encrypted. A couple of weeks later, EMC sent out notice to these individuals informing them of the theft.

Real parties in interest (Plaintiffs) are a few of the individuals whose names were on the index. They filed the underlying…