Commissioner of Mental Health & Addiction Services v. Freedom of Information Commission

Summary

The court held that a police report documenting a postmortem investigation at a state mental health facility was not a privileged psychiatrist-patient communication or record under the governing statutory definition, so FOIA required its disclosure. HIPAA did not independently bar disclosure because FOIA constituted a legal mandate permitting disclosure under the Privacy Rule, but patient names, dates of birth, and home phone numbers had to be redacted because those details were outside the request. Justice Keller, dissenting, would have treated the report as privileged and barred disclosure, while Chief Justice Robinson, concurring in part and dissenting in part, would have required additional redaction of the deceased patient’s psychiatric diagnosis.