Congratulations to Partner Tara Taylor & Associate Benjamin Beasley on their Recent Appellate Win!

Representing Park West Health Systems, Inc., and Michael Johnson, Mrs. Taylor and Mr. Beasley recently won the appeal in David Cofield v. Park West Health Systems, Inc. et al. in the Maryland Court of Special Appeals. 

This case arose from a robbery that occurred at Park West Health Systems in Baltimore City on March 30, 2015.  Michael Johnson, a Park West employee, was robbed at gunpoint by an unknown assailant.  Following the assault, Mr. Johnson provided Park West with a description of the assailant’s clothing, which Park West determined to match that of David Cofield—a Park West patient who reportedly exited the facility shortly before the robbery. Park West provided this information to Mr. Johnson as well as law enforcement authorities.

A Baltimore Police Department (“BPD”) detective, leading the investigation, presented Mr. Johnson with a photo array, which included Mr. Cofield’s photograph. Mr. Johnson failed to identify anyone from the photo array, but the detective nonetheless issued a warrant for Mr. Cofield. The detective provided a partial investigative file to the Office of State’s Attorney, which failed to include the negative results of the photo array. The State’s Attorney’s Office indicted and incarcerated Mr. Cofield for four months until the prosecuting attorney learned about the negative photo array and dismissed the charges. 

Following his release, Mr. Cofield filed a nine-count Complaint against Park West, contending that Park West violated HIPAA regulations and his privacy rights by releasing his photograph and description. Mr. Cofield also filed a six-count Complaint against the BPD and lead detective for civil rights violations. In trial court, Mr. Cofield reached a settlement with the BPD and lead detective, but Mrs. Taylor and Mr. Beasley moved for summary judgment on behalf of Park West, arguing that Park West was not negligent because it did not breach a duty owed to Mr. Cofield under HIPAA, but even if it did, any such breach was not the proximate cause of Mr. Cofield’s alleged injuries. The trial court agreed with Park West and granted summary judgment, concluding that there was no evidence that any negligence on the part of Park West proximately caused the injuries to Mr. Cofield, especially given the negative photo array. 

Mr. Cofield appealed to the Maryland Court of Special Appeals, arguing that Park West’s negligence in making the disclosure lead to his wrongful arrest, conviction, and incarceration. Park West countered that its disclosure did not proximately cause Mr. Cofield’s injuries, the injuries were not a reasonably foreseeable result of the alleged negligence, the injuries could be attributed to other superseding causes, and that HIPAA was not designed to prevent the type of harm suffered by Mr. Cofield. The Court of Special Appeals agreed with Park West, finding that Park West and Mr. Johnson acted in good faith in response to a felony, their actions did not proximately cause Mr. Cofield’s injury, and the harm suffered by Mr. Cofield was not the type of harm that HIPAA was designed to prevent. Park West merely disclosed Mr. Cofield’s name, photograph, and a physical description—nothing concerning his treatment. Therefore, the Court concluded that the trial court correctly granted judgment in favor of Park West and Mr. Johnson.

Congratulations to our attorneys on their win!