Stewart v. Parkview Hospital

Dist. Ct. did not err in granting defendants-hospital and police officials’ motion for summary judgment in plaintiff’s section 1983 claim, alleging that defendants-police and hospital officials violated his 4^th Amendment rights and violated HIPAA provisions when defendants-police officials requested and defendants-hospital official disclosed without plaintiff’s permission results of his blood-test results for presence of alcohol that ultimately led to plaintiff pleading guilty to charge of operating vehicle while intoxicated. Plaintiff could not proceed on any HIPAA claim, since HIPAA provides plaintiff with no private right of action. Moreover, defendants-police officers possessed qualified immunity with respect to plaintiff’s 4^th Amendment claim, where: (1) Indiana statute gave defendants ability to obtain blood-test results from medical personnel; and (2) police officials had no reason to believe via case law that 4^th Amendment barred police from seeking results of blood test that doctor had ordered for medical purposes.