Z D v. Community Health Network

Summary

The court held that the hospital was not entitled to summary judgment on the patient's public-disclosure privacy claim because intent is not required and the evidence supported conflicting inferences about whether the disclosure was sufficiently likely to become public knowledge. The court also held that emotional-distress damages are unavailable on the patient's negligence claim absent a direct physical impact, but that her claims for pecuniary damages and proximate cause remained for trial. The judgment was therefore affirmed in part, reversed in part, and remanded.