Racz v. Mayo Clinic

Background

Jennifer M. Racz, M.D., alleged that Dr. Ahmad Sughayer, a Mayo physician, improperly accessed and viewed the medical records of approximately 1,600 Mayo patients, including Racz. Her records included images taken while she was fully or partially nude in connection with obstetrical, gynecological, and dermatological treatment. Racz alleged that Sughayer had no legitimate reason to access her records and that Mayo was responsible for his conduct because he was its employee. She asserted a Minnesota Health Records Act claim in Count Eight and a Minnesota common-law invasion-of-privacy claim in Count Nine.

The case also included separate claims concerning adverse actions taken against Racz as a Mayo employee. Mayo’s motion addressed only Counts Eight and Nine; the court noted that the employment-related claims, Counts One through Seven, would proceed in the case regardless of the motion’s outcome.

Mayo’s Motion

Mayo moved to dismiss or, alternatively, stay Counts Eight and Nine under the Colorado River abstention doctrine. That doctrine allows a federal court to refrain from exercising its jurisdiction in limited circumstances when a parallel state proceeding exists and exceptional circumstances justify doing so. Mayo relied on three Minnesota state-court cases involving access to Mayo patients’ medical records: two putative class actions and one individual damages action. Mayo argued that judicial economy and litigation efficiency favored requiring Racz to pursue her claims as a class member in one of the state cases.

Court’s Analysis

The court first held that the state cases were not parallel to Racz’s federal case. The individual state damages suit could not dispose of Racz’s claims because she was not a party to it. The two putative class actions also could not presently dispose of her claims because class certification had not yet occurred. The court further noted that Racz might be able to opt out of one proposed class, and that the possibility of a future mandatory class in the other case did not justify putting her claims on hold.

The court separately concluded that the six factors used by the U.S. Court of Appeals for the Eighth Circuit did not show exceptional circumstances. There was no property over which one court had jurisdiction, the federal forum was not inconvenient, and the possibility of duplicative discovery, motions, and trials was not unusual enough to justify abstention. The state cases had not progressed meaningfully farther than the federal case, Racz’s state-law claims were suitable for a federal forum, and the state court’s adequacy did not override her choice to pursue her claims individually and in federal court.

The court also explained that, in a damages action, the Colorado River doctrine may support a stay but not dismissal. Because the court found neither parallel proceedings nor exceptional circumstances, it did not abstain from exercising jurisdiction.

Disposition

Judge Eric C. Tostrud ordered that Mayo Clinic’s Motion to Dismiss or, Alternatively, Stay Counts Eight and Nine was DENIED. The order did not decide whether Racz would ultimately prevail on her Health Records Act or invasion-of-privacy claims.