New York Law Review

Tag: Public Health Law § 18

  • Mantica v. New York State Department of Health, 94 N.Y.2d 58 (1999): Patient Access to Medical Records Under FOIL

    Mantica v. New York State Department of Health, 94 N.Y.2d 58 (1999)

    A patient may obtain their own medical records from a state agency under New York’s Freedom of Information Law (FOIL), even with Public Health Law § 18(6)’s restrictions on third-party redisclosure, unless those records contain information that could cause substantial harm to the patient or others, or contain privileged doctor’s notes.

    Summary

    James Mantica sought his medical records from the New York State Department of Health (DOH) under FOIL after receiving allegedly deficient medical care. DOH denied the request, citing Public Health Law § 18(6), which restricts third-party redisclosure of patient information. The New York Court of Appeals held that Mantica was entitled to his records because the intent of Public Health Law § 18(6) was not to prevent patients from accessing their own medical records, but rather to prevent disclosure to other third parties. The Court emphasized that FOIL mandates broad disclosure unless a specific statutory exemption applies and the agency demonstrates that the material qualifies for exemption.

    Facts

    James Mantica received allegedly deficient medical care at St. Peter’s Hospital, leading to the amputation of his legs. His wife filed a complaint with the DOH. Subsequently, the Manticas commenced a medical malpractice action against several physicians and the hospital. They requested Mantica’s medical records from DOH, who provided redacted versions of some documents. When a second, more detailed request invoking FOIL was denied, the Manticas initiated a CPLR article 78 proceeding to compel disclosure.

    Procedural History

    The Supreme Court initially ordered disclosure, except for quality assurance review activities. The Appellate Division affirmed, stating that denying a patient their own health information was illogical. The New York Court of Appeals granted DOH leave to appeal, limiting the scope to the production of Mantica’s medical records.

    Issue(s)

    Whether a patient can obtain their own medical records from a state agency under FOIL, notwithstanding Public Health Law § 18(6)’s prohibition against redisclosure of patient information by third parties.

    Holding

    Yes, because the legislative intent of Public Health Law § 18(6) was to protect patient privacy by preventing disclosure to third parties, not to deny patients access to their own medical information. Public Health Law § 18(3) and (4) might provide a specific statutory exception to FOIL, and the patient might be required to obtain the records directly from the health care provider pursuant to section 18, if the records contain information that could cause substantial harm to the patient or others, or contain privileged doctor’s notes.

    Court’s Reasoning

    The Court of Appeals reasoned that FOIL imposes a broad standard of open disclosure on government agencies, and documents are presumptively discoverable unless a specific statutory exemption applies. The burden rests on the agency to demonstrate that the requested material qualifies for exemption. DOH argued that Public Health Law § 18(6) provided such an exemption. However, the court determined that the intent of § 18(6) was to prevent disclosure of confidential medical records to third parties, not to patients themselves. The Court cited the legislative record, including a DOH memorandum recommending approval of the bill, which stated, “There is no legitimate reason to withhold information related to a person’s physical health from that person particularly when insurers, government agencies and employers are routinely granted access.” The Court clarified that a patient’s right to access their records is not absolute; Public Health Law § 18(3) allows denial of access if the information could cause “substantial and identifiable harm” or contains privileged doctors’ notes, with a detailed mechanism for administrative and judicial review. However, since there was no allegation of harmful information or privileged notes in this case, § 18(3) and (4) did not provide an exemption to FOIL. The Court emphasized that the patient’s right to obtain the records under FOIL is not diminished by the possibility of obtaining them directly from the hospital under § 18. The Court stated, “Information so disclosed should be kept confidential by the party receiving such information and the limitations on such disclosure in this section shall apply to such party.”