Yath v. Fairview Clinics, N.P.

Yath (plaintiff) was treated for a sexually transmitted disease at a clinic (defendant). A clinic employee, related to Yath's ex-husband, accessed her file without authorization, learned her diagnosis and details about her new partner, and passed the information to a coworker, who disclosed it further, including to Yath's ex-husband. A MySpace page soon appeared, created at a business employing the first employee's sister, exposing Yath's name, photo, diagnosis, and an accusation of infidelity. Yath sued the clinic and several individuals for invasion of privacy, related torts, and violation of a Minnesota statute governing unauthorized disclosure of medical information; she later dismissed the claims against the individuals most directly responsible for the webpage. The trial court granted summary judgment to the clinic and a remaining employee, and Yath appealed.

Whether a state law prohibiting the unauthorized disclosure of an individual's private medical information may be preempted by the federal Health Insurance Portability and Accountability Act (HIPAA) if the state law is contrary to HIPAA's purposes.