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On December 15, 2020, in Menorah Park v. Rolston, the Ohio Supreme Court declined to overturn Biddle v. Warren Gen. Hosp., 86 Ohio St.3d 395 (1999). As a result of this decision, providers will remain subject to liability under a private cause of action for breach of medical confidentiality if they are found improperly disclosing medical records. Background In Biddle, the Supreme Court judicially created a new, private cause of action that can be brought by a patient (or the patient’s representative) against a health care provider in the event of the provider’s unauthorized disclosure of the patient’s private medical information. The Ohio Supreme Court decided ....