Doe v. Community Health Plan—Kaiser Corp.
Plaintiff sued Ericka Klein, Community Health Plan—Kaiser Corporation (CHP), and Christen Adey for damages due to the alleged disclosure of confidential medical information from her patient file. The Supreme Court initially granted partial summary judgment against Adey but dismissed several claims against CHP and Klein. On appeal, the Court affirmed the denial of plaintiff's motion for partial summary judgment but reversed the grant of CHP’s motion for summary judgment on the first cause of action, which alleged breach of confidentiality. The appellate court upheld the dismissal of the remaining causes of action, including those for statutory breach of confidentiality and intentional infliction of emotional distress, clarifying the scope of direct corporate responsibility for employee actions breaching confidentiality.