Articles From Michael F. Dahlen | Illinois State Bar Association

Bagent v. Blessing Care Corporation: How to avoid a hospital’s potential liability for wrongful disclosure of confidential patient information by an employee By Michael F. Dahlen Health Care Law, June 2007 In its recent decision in Bagent v. Blessing Care Corporation, the Illinois Supreme Court held, in a case of first impression, that a hospital was not vicariously liable for the wrongful disclosure of confidential patient medical information by an employee phlebotomist because the disclosure was outside the scope of the employee’s employment.

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