QT, Inc. v. Mayo Clinic Jacksonville (Summary)

PRIVACY

QT, Inc. v. Mayo Clinic Jacksonville, No. 05 C 6387 (N.D. Ill. May 15, 2006)

The United States District Court of the Northern District of Illinois denied the manufacturer of an ionized bracelet access to the questionnaires of participants in a hospital’s clinical study of the product. The hospital and manufacturer had agreed to conduct a study on the effectiveness of the bracelets. After the hospital issued a report finding the bracelets were ineffective, the manufacturer brought suit alleging, among other things, commercial disparagement, tortious interference, and deceptive trade practices. During discovery, the manufacturer sought the participants’ questionnaires. The hospital agreed to provide the surveys only if the names of the participants were redacted, claiming the questionnaires contained confidential medical information. The district court agreed, finding the participants in the study were akin to patients and that their medical information was protected under state privacy laws. However, the district court did find the manufacturer was entitled to the names of the participants in the study, as long as they were not traceable to individual medical information. In its ruling, the court applied state law rather than the HIPAA Privacy Rule because it concluded that state law was more protective of patients’ privacy rights.