Dittman v. University of Pittsburgh Medical Center
Pennsylvania Supreme Court
649 Pa. 496 (Pa. 2018)
- Written by Jamie Milne, JD
Facts
The University of Pittsburgh Medical Center (UPMC) (defendant) was subject to a data breach in which its employees’ personal information was stolen from its computer systems. Barbara Dittman and other UPMC employees (the employees) (plaintiffs) sued UPMC, alleging, among other things, that UPMC was liable for negligence. They argued that (1) UPMC had a duty to reasonably protect the personal information it required employees to provide, (2) UPMC breached that duty by failing to adopt adequate security measures, and (3) UPMC’s breach was the actual and proximate cause of harm because the stolen information was used to file fraudulent tax returns and created an imminent risk of other identity theft. UPMC moved to dismiss the negligence claim on two bases: it argued (1) that it did not have a legal duty to safeguard the employees’ personal information and (2) that the economic-loss doctrine precluded recovery because the employees had suffered only economic harm, without any accompanying physical harm or property damage. The trial court agreed, dismissing the negligence claim. The state appellate court affirmed, and the employees appealed.
Rule of Law
Issue
Holding and Reasoning (Baer, J.)
What to do next…
Here's why 899,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 47,000 briefs, keyed to 994 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
