Keyse v. Cleveland Clinic Found.

Citations

• 2024 Ohio 2806

Syllabus

Biddle claim unauthorized disclosure third party summary judgment motions in limine. - A Biddle claim requires proof of the unauthorized, unprivileged disclosure to a third party of nonpublic medical information that a physician or hospital has learned within a physician-patient relationship the trial court did not err in granting summary judgment to defendant hospital on plaintiff's Biddle claim where there was no evidence that the defendant had intentionally or unintentionally disclosed plaintiff's medical information to anyone rather, the evidence was clear that plaintiff's sister, who was an employee of defendant hospital, had accessed plaintiff's medical information without authorization to do so any argument regarding the trial court's granting of appellee's pre-trial motions in limine was rendered moot in light of appellate court's judgment affirming the trial court's grant of summary judgment to appellee.