Iowa Court: proof of disclosure not sufficient to support damages

Jeff Drummon of HIPAA blog points to an Iowa case decided this month: John Doe v. Central Iowa Health System d/b/a Iowa Health Des Moines d/b/a Iowa Methodist Medical Center and d/b/a Iowa Lutheran Hospital (pdf). In this case, although the plaintiff seemingly convinced the jury that his records had been improperly disclosed, he didn’t demonstrate actual harm, providing no expert testimony on the impact of the breach on his health and well-being, etc.

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