Edward Capocy v. Susan Kirtadze and Amtrak Railroad
Docket: 98-2765
Court: Court of Appeals for the Seventh Circuit; July 1, 1999; Federal Appellate Court
Edward Capocy sued Amtrak under the Federal Employees Liability Act (FELA) in 1994 for injuries, including severe mental anguish. While the case was pending, Amtrak engaged Comprehensive Rehabilitation Associates, Inc. (CRA) for Capocy's vocational rehabilitation. Capocy signed a consent form allowing CRA to access his medical records, which included reports sent to Amtrak claims adjuster Susan Kirtadze. During this period, he applied for social security disability benefits, leading to an evaluation by Dr. Richard Katz, who noted Capocy's hostility towards Amtrak and the judicial system. This report was shared with Shou and subsequently forwarded to Kirtadze.
Capocy settled his FELA claim for $260,000 in April 1995, signing a general release relinquishing any claims related to existing injuries. He was aware that Shou had sent Katz's report to Kirtadze when he signed the release. In December 1996, Capocy filed a lawsuit in Illinois state court against Kirtadze, Amtrak, Shou, and CRA, claiming violations of his privacy rights under the Illinois Mental Health and Developmental Disabilities Confidentiality Act. Amtrak moved the case to federal court, where the district court granted summary judgment for the defendants, ruling that Capocy's release barred his claim since he was aware of the Confidentiality Act issue at the time of settlement. Capocy contended that the intent behind the release should be determined by a jury and argued that the release did not apply to claims not specifically mentioned. The court upheld the summary judgment, agreeing with the district court's findings.
Grants of summary judgment are reviewed de novo, as established in Tesch v. County of Green Lake. Summary judgment is appropriate when the evidence shows no genuine issue of material fact, with the moving party entitled to judgment as a matter of law (Fed. R. Civ. P. 56(c)). In assessing whether a genuine issue exists, all facts are viewed in favor of the nonmoving party, and reasonable inferences are drawn for that party. However, mere allegations of factual disputes or metaphysical doubts do not defeat a motion for summary judgment. A district court's grant of summary judgment may be affirmed for any reason supported by the record.
Regarding medical record confidentiality, although it is generally protected, individuals may waive this right, and courts cannot retroactively reinstate protections that have been relinquished. In this case, under Illinois law, the disclosure of Katz's report was part of Capocy's Federal Employers Liability Act (FELA) proceedings, leading to Capocy waiving the protections of the Confidentiality Act by signing a general release during the settlement of his FELA suit.
Federal courts handling diversity cases apply state law principles, as seen in Shirley v. Russell. In Illinois, a release is viewed as a contract whereby one party relinquishes claims against another, governed by contract law. The parties' intent, derived from the release language and transaction circumstances, dictates its scope and effect. Courts will not interpret a release to encompass claims not anticipated by the parties. If both parties are aware of an additional claim at the time of signing, the release language will apply to that claim. However, specific language in the release can limit the general terms to the claims explicitly referenced.
Capocy asserts that by naming specific statutes in the release, he is only waiving claims under those laws, arguing that his claim regarding the disclosure of mental health records under the Confidentiality Act is not barred. The court disagrees with this assertion.
The general release signed by Capocy on April 20, 1995, explicitly relinquishes all claims and liabilities, both known and unknown, related to injuries sustained during his employment around March 29, 1994, including those under the Federal Employers Liability Act (FELA), the Americans with Disabilities Act, the Rehabilitation Act of 1973, and various state and local disability laws. Capocy contends that the inclusion of these statutes limits the release to claims arising solely under them. He cites the Illinois court case Carona, which interpreted a release as limiting claims to those that could arise in the future from a specified injury date. However, the court rejects Capocy's argument, stating that the reference to the statutes does not limit the general release. Illinois courts interpret releases under contract law principles, giving significance to every term. The phrase "but without limitation of the foregoing" and the inclusion of the statutes within a broader context indicate an intention to encompass all claims, not just those arising under the specified statutes. Therefore, the language of the release suggests a comprehensive settlement of claims, contrary to Capocy's interpretation.
The release signed by Capocy aimed to achieve complete resolution of disputes, and allowing him to raise claims known at the time of signing would undermine the efficacy of settlement agreements. The court found that references to specific statutes did not limit the types of claims Capocy agreed to relinquish, particularly those related to his employment and subsequent Federal Employers Liability Act (FELA) claim. Capocy's confidentiality claim stemmed from actions connected to his FELA suit, as Amtrak engaged CRA to evaluate his injuries, and Capocy had consented to the sharing of his medical records. The disclosure of these records, including a report from Katz, occurred because of the FELA claim, thus linking it to the release. Capocy's acknowledgment of the circumstances surrounding the disclosure at the time he signed the release meant he waived his right to pursue this claim. Illinois law interprets general releases to encompass claims known to the parties at the time of execution. Consequently, the district court's summary judgment in favor of Kirtadze and Amtrak was affirmed, confirming that Capocy forfeited his confidentiality claims related to his FELA action.
Under the Illinois Mental Health and Developmental Disabilities Confidentiality Act, disclosure of records requires written consent from individuals entitled to access those records, as specified in Section 4. The consent must include details about the recipient, purpose, nature of the information, rights to inspect and copy, consequences of refusal, expiration date, and the right to revoke consent. The document signed by Capocy lacks the required information, rendering it insufficient as valid consent under the Act. Therefore, it does not influence the case outcome as intended.
Additionally, Capocy's general release indicates he intends to be legally bound in exchange for $260,000, minus specific deductions. This release discharges National Railroad Passenger Corporation and associated parties from all claims related to his employment and injuries sustained on March 29, 1994, including liabilities under federal and state disability laws. Furthermore, Capocy agrees to resign from his position as part of the settlement agreement.
