Improper disclosure of a patient's personal and/or medical information can occur in unique situations. Two recent cases, neither involving improper computer disclosure, are instructive on how courts are being asked to expand legal duties beyond traditional boundaries.

In Suzanne Bagent v. Blessing Care Corp., d/b/a Illini Community Hospital, et al., __ N.E. 2d ___, 2007 WL 121319 (Ill 2007) (not yet released for publication), the Illinois Supreme Court found that a hospital employee's improper disclosure of confidential information about a patient did not expose the hospital to liability under a theory of respondeat superior....

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