Humphers v. First Interstate Bank of Oregon

Ramona Humphers (plaintiff) gave her newborn up for adoption decades earlier, with the birth records sealed and known only to Humphers, her mother, and her treating physician, Dr. Mackey (defendant); twenty-one years later, Humphers's adopted daughter sought out Mackey to find her biological mother, and Mackey provided information (some false) that helped the daughter successfully locate Humphers, causing Humphers significant distress. Humphers sued Mackey's estate, managed by First Interstate Bank of Oregon (defendant), on five theories including outrageous conduct, professional negligence, breach of confidential relationship, invasion of privacy, and breach of contractual secrecy; the trial court granted the Bank summary judgment on all theories, and the court of appeals affirmed except as to the breach-of-confidence and invasion-of-privacy theories. The Bank appealed.