Head v. Colloton

William Head (plaintiff) had leukemia. In 1982, Head contacted the bone-marrow-transplant unit at the University of Iowa Hospitals and Clinics (the hospital) (defendant) to inquire about the unit’s bone-marrow-transplant registry. Head discovered that the registry included the name of a woman (the listed donor) who had a tissue type that made the listed donor a potentially suitable bone-marrow donor to Head. The listed donor had earlier had her tissue typed to determine whether she was a suitable blood platelet donor for a sick family member. The listed donor was added to the registry without her knowledge. After Head contacted the bone-marrow unit, a representative from the unit contacted the listed donor. The listed donor said she was not interested in being a bone-marrow donor and that she would only consider being a donor for a family member. Head asked the bone-marrow unit to reach out to the listed donor again to make a specific inquiry on Head’s behalf or else to disclose the listed donor’s identity to him so that Head could contact her himself. The hospital refused. Head sued the hospital, seeking an injunction requiring the hospital to disclose the identity of the listed donor to the court or to Head’s attorney so that a letter could be written to the donor notifying her of her suitability to be a donor for Head and asking if she would consider being a donor. The court sided with Head, and ordered the hospital to disclose the listed donor’s identity. The hospital appealed and was granted a stay of the court order to disclose the identity of the listed donor. The hospital conceded that because the hospital was a state hospital, its records were public records. However, the hospital claimed that its registry was confidential under Iowa law.