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Middlebrooks v. State Board of Health
Alabama Supreme Court
710 So. 2d 891 (1998)
Alabama had a statute requiring certain providers to report the name and address of anyone with a suspected or confirmed case of HIV or AIDS to the Alabama State Board of Health (the state board) (plaintiff). The law applied to doctors, dentists, nurses, coroners, hospital administrators, nursing-home administrators, laboratory directors, school principals, and day-care directors in the state. However, the law did not apply to entities that sold confidential HIV test kits or to out-of-state testing laboratories that provided blind HIV test results. Dr. Mark Middlebrooks (defendant) treated patients with infectious diseases, including HIV and AIDS. Middlebrooks reported statistical data to the state board about the HIV and AIDS cases he encountered in his practice, but he refused to provide the patients’ names or addresses. The state board sued Middlebrooks, relying on the statute to force him to provide names and addresses. Middlebrooks argued that the statute violated the Equal Protection Clause in the United States Constitution. Specifically, Middlebrooks claimed that the statute unreasonably forced some medical and child-care providers to report information, but did not require the similarly situated confidential-test sellers or out-of-state labs to provide anything. The trial court ordered Middlebrooks to disclose the patients’ names and addresses to the state board. Middlebrooks appealed.
Rule of Law
Holding and Reasoning (Maddox, J.)
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