Doe v. Medlantic Health Care Group, Inc.

John Doe (plaintiff) had not told his employer that he was HIV positive. Doe worked as a janitor for a company that provided cleaning services to the U.S. Department of State. A State Department co-worker, Tijuana Goldring, was also a temporary receptionist at the Washington Health Center (WHC), a facility owned by Medlantic Health Care Group (defendant). Doe went to the emergency room at WHC complaining of severe headaches, nausea, and high fever. Doe retuned to WHC for a follow-up appointment and stopped by Goldring’s desk to say hello. Goldring asked for the spelling of Doe’s last name so that she could send him a get-well card, which she never sent. Goldring informed other workers at the State Department that she learned from the hospital that Doe was HIV-positive. When Doe returned to work, he was teased, ridiculed, and shunned by his co-workers and others throughout the State Department. Once Doe learned that Goldring was the source of the disclosed information, he filed a complaint against Medlantic and Goldring alleging tort claims of invasion of privacy based on Goldring’s disclosure of Doe’s HIV-positive status and breach of confidential relationship based on WHC’s negligence in permitting Goldring access to confidential patient information. After a trial, the jury found Medlantic liable for breach of confidential relationship and awarded Doe $250,000 in damages. The jury found against Doe on his invasion of privacy claim against Goldring because the disclosure was not within the scope of Goldring’s employment with WHC. Medlantic filed a motion for judgment arguing that Doe’s claims were barred by the statute of limitations. The trial court granted Medlantic’s motion and Doe appealed.