John Doe is out-of-luck for a romantic Valentine’s Day this year. He recently discovered that his protected health information regarding treatment for a sexually transmitted disease (“STD”) was sent to his girlfriend. While being treated for an STD at a New York clinic, John Doe was recognized by one of the clinic’s nurses. Unfortunately for John Doe, the nurse knew that he was the boyfriend of her sister-in-law. She discovered that he was being treated for an STD, and she contacted her sister-in-law via text message to inform her of his medical condition. John Doe learned of the nurse’s text messages disclosing his STD when his girlfriend forwarded them directly to him while he was still at the clinic. The clinic fired the nurse for breaching John Doe’s confidential information. However, the New York Court of Appeals recently found that the clinic is not liable for the nurse’s breach of confidential information.

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