Griffin-Robinson v. New York City Health and Hospitals
- Laura Swain
- 1:21-cv-04881
- U.S. District Court · Southern District of New York
- 7
In Griffin-Robinson v. New York City Health and Hospitals, Judge Swain dismissed the complaint for failure to state a claim and declined state-law jurisdiction.
Sonja Griffin-Robinson’s federal claims were dismissed, including her HIPAA claims and any federal claims against Ronald Cobb and Christopher Pena; the court declined to hear any state-law claims.
What happened
In Griffin-Robinson v. New York City Health and Hospitals, Sonja Griffin-Robinson, representing herself, alleged that hospital employees disclosed her medical information, spread false statements, and helped remove her from hospital care. She sought millions of dollars in damages and asked the court to stop related conduct involving state-court proceedings.
The court ruled that the federal medical-privacy claims failed because the Health Insurance Portability and Accountability Act does not allow an individual to bring a private lawsuit. It also dismissed any federal claims against Doctors Ronald Cobb and Christopher Pena because the complaint did not identify a recognizable federal claim. After dismissing the federal claims, the court declined to consider any state-law claims.
Judge Laura Taylor Swain dismissed the complaint for failure to state a claim, denied leave to amend, and denied fee-free status for an appeal because the court certified that an appeal would not be taken in good faith. The court also warned that repetitive future lawsuits could lead to restrictions on filing without prior permission.
The detailed version
- Griffin-Robinson v. New York City Health and Hospitals · No. 1:21-cv-04881
- Laura Swain
- July 6, 2021
Background
Sonja Griffin-Robinson filed the case without a lawyer and was allowed to proceed without paying the filing fee. She alleged that social worker Lise Wilson disclosed information about her medical condition to Westchester County Assistant District Attorney Adrian Murphy without authorization and spread that information at Harlem Hospital, which is operated by New York City Health + Hospitals. She also alleged that Wilson made or repeated false statements about a criminal charge and that Doctors Ronald Cobb and Christopher Pena participated in efforts to have her removed from the hospital so they would not have to treat her.
The complaint sought $2.8 million from Wilson, $275,000 each from Cobb and Pena, and $11 million from Mitchell Katz, identified as the President and CEO of New York City Health + Hospitals. It asserted a claim under the Health Insurance Portability and Accountability Act of 1996, or HIPAA, and appeared to assert other federal and state claims. The complaint also asked the court to stop actions involving the Westchester County District Attorney’s Office and a state court. The opinion stated that the complaint did not explain the nature of the state-court proceedings or whether Griffin-Robinson had been charged with a crime.
Legal standards
Because Griffin-Robinson was proceeding without prepaying fees, the court was required to screen the complaint under 28 U.S.C. § 1915(e)(2)(B). The court had to dismiss claims that were frivolous or malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also had to dismiss if it lacked subject-matter jurisdiction. Although courts read self-represented complaints generously, a complaint still must provide enough factual detail to make a legally valid claim plausible.
HIPAA claims
The court noted that Griffin-Robinson had raised similar HIPAA allegations in a prior related proceeding. The court explained that HIPAA does not create a private right of action, meaning that an individual cannot use HIPAA to bring a damages lawsuit directly against alleged violators. The court therefore dismissed the HIPAA claims against Wilson and the apparent HIPAA claims against Katz and possibly New York City Health + Hospitals for failure to state a claim.
The opinion also noted that HIPAA can permit covered entities to disclose protected health information without patient consent in certain circumstances, including in response to a court order. The court did not decide whether any particular disclosure in this case was authorized on that basis because it dismissed the claims for the separate reason that HIPAA does not permit a private lawsuit.
Claims against Cobb and Pena
The court found it unclear what federal claims Griffin-Robinson was asserting against Cobb and Pena. Even after reading the complaint liberally, the court could not identify a legally cognizable federal claim against either doctor. It dismissed any federal claims against Cobb and Pena for failure to state a claim.
State-law claims and amendment
After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over any state-law claims. Supplemental jurisdiction is the federal court’s discretionary authority to hear related state-law claims after federal claims are part of the case; the court concluded that this authority should not be used here because no federal claims remained.
The court denied leave to amend because it concluded that the defects in the complaint could not be cured by amendment. It also warned that repetitive litigation could lead to an order barring Griffin-Robinson from filing new actions without paying the filing fee unless she first obtained the court’s permission.
Disposition
The court dismissed the complaint for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii). It declined to exercise supplemental jurisdiction over any state-law claims. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. Judge Laura Taylor Swain signed the order.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.