Warwick Lodge No. 7, Fraternal Order of Police v. City of Warwick
Docket: No. 97-398-A
Court: Supreme Court of Rhode Island; January 15, 1998; Rhode Island; State Supreme Court
The defendants—City of Warwick, Warwick Police Department, Warwick Board of Public Safety, and William E. DeFeo—appealed a Superior Court order that granted a preliminary injunction to the plaintiffs. The plaintiffs filed a complaint for declaratory judgment, claiming that a provision in their collective bargaining agreement violated the Confidentiality of Health Care Information Act by requiring employees to sign a release authorizing the city to obtain extensive medical information from their treating physicians. The release permitted the city to access all medical information related to the employee's injury or illness and information about healthcare costs. The trial justice ruled that the release's scope was overly broad, infringing on the act's limited access provisions, which dictate that third parties must have restricted access to a patient’s confidential information based on a "need to know." The judge also found the release of cost information unnecessary. In assessing the injunction, the trial justice weighed several factors, concluding that the plaintiffs showed a likelihood of success on the merits, that the violation of the health care information act posed a risk of irreparable harm without adequate legal remedy, and that the potential harm to plaintiffs outweighed the minor inconvenience to the defendants of revising the release to comply with the act. The appellate court affirmed the trial justice's decision, finding no abuse of discretion, and denied the defendants' appeal. A typographical error was noted regarding the use of "employers" instead of "employees" in the release context.