Lawson v. Halpern-Reiss

Elizabeth Lawson (plaintiff) was intoxicated. Lawson got a laceration on her arm, so she drove herself to the Central Vermont Medical Center (the hospital) (defendant) for treatment. The charge nurse detected alcohol on Lawson’s breath. Hospital staff administered a blood-alcohol-concentration test on Lawson, which revealed a blood-alcohol level of .215, over two and one-half times the legal limit. Lawson received treatment for her laceration, and she was cleared for discharge. Because the charge nurse knew that Lawson did not have a ride home from the hospital, the charge nurse informed a police officer on duty in the emergency room that Lawson had driven herself to the hospital, she was about to drive herself home, and she was intoxicated. The police officer arrested Lawson on suspicion of driving while intoxicated although the charge was later dismissed. Two years later, Lawson sued the charge nurse and the hospital. Lawson alleged damages stemming from the charge nurse’s violation of the standard of care for medical providers in negligently disclosing information obtained during Lawson’s medical treatment and from the hospital’s lack of training and policies regarding information disclosure. The charge nurse and the hospital moved for summary judgment, arguing that a tort action for the disclosure of medical information did not exist. The trial court granted summary judgment in favor of the hospital; the charge nurse had already been dismissed from the case. Lawson appealed, arguing that the court ought to recognize a common-law private remedy for breach of confidentiality by a medical provider.