Tyson v. Ohio Dept. of Rehab. & Corr.

Citations

• 2024 Ohio 1481

Syllabus

Inmate medical information disclosure breach of confidence Biddle intentional infliction of emotional distress. The magistrate found that there was no breach of confidence when defendant's Prison Rape Elimination Act (\PREA\) Coordinator shared plaintiff's gender identity with defendant's Mental Health Manager as required by defendant's PREA policy or when defendant provided plaintiff with records related to a conversation regarding plaintiff's gender identity. The magistrate determined that plaintiff's intentional infliction of emotional distress claim was subsumed by the tort of breach of confidence and if it had not been, the greater weight of the evidence demonstrated that defendant was acting in good faith to comply with policies and plaintiff's records requests, not to do serious emotional harm to plaintiff. Therefore, the magistrate recommended judgment for defendant.