Justices: Hospital room number is health record under state law

In Brief

  • Minnesota Supreme Court held that a patient’s hospital room number and status as a patient qualify as a health record under the Minnesota Health Records Act.
  • The ruling stemmed from Allina Health‘s disclosure of Justin Holtzbauer’s hospital location after he opted out of the facility directory.
  • Holtzbauer alleged emotional distress after his former spouse obtained his room number and visited him despite his objections.
  • The court acknowledged potential operational challenges for hospitals but said any statutory exceptions should be created by the Legislature.

A man who being treated at a hospital opted out of the facility’s directory, but a medical professional shared his room number and the fact that he was a patient anyway. The Minnesota Supreme Court, affirming the Minnesota Court of Appeals, held that information that a patient is in a particular room in a hospital is a health record.

Justin Holtzbauer, injured while working as a tree trimmer, received treatment at Allina’s Mercy Hospital in Coon Rapids. Holtzbauer opted out of the facility directory. Under Allina policy, this prevented the disclosure of his presence. Holtzbauer’s former spouse, H.H., learned that he was hospitalized. However, Holtzbauer specifically told her not to visit.

They texted, and then Holtzbauer did not reply to H.H. H.H. began calling local hospitals and discovered through an employee at United Hospital, an Allina facility, that Holtzbauer was at Mercy Hospital. The employee gave H.H. his room and bed number…

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