Whether patients may obtain their own medical records from a state agency pursuant to New York State's Freedom on Information Law despite the prohibition of Public Health Law § 18(6) against redisclosure of patient information by third parties.

Yes. The purpose of Public Health Law § 18(6) is not to prevent a patient from obtaining his or her own health care information, but to prevent disclosure of such information to third parties.

In 1993, Plaintiff James Mantica received allegedly deficient medical care at St. Peter's Hospital in Albany, New York, which resulted in the amputation of both his legs.

In 1995, Plaintiffs filed a medical malpractice action in Supreme Court, and requested from Defendant copies of their "complete file concerning the investigation of the ... complaint...." Defendant provided redacted versions of some of the documents requested. Plaintiffs later filed a more detailed request for the DOH file, invoking New York State's Freedom of Information Law, which Defendant initially refused. After an administrative appeal, Defendant provided some additional information, but cited statutory exemptions to FOIL and stated that the medical records should be obtained form the hospital pursuant to Public Health Law § 18. Plaintiffs then brought this action seeking an annulment of Defendant's determinations and disclosure of Plaintiff's medical records pursuant to FOIL.

Supreme Court ordered the disclosure of the requested information, concluding that the purpose of the Public Health Law's prohibition on redisclosure is to protect the subject patient, and that the patient's right of access to the information outweighed the potential harm disclosure could cause. Supreme Court refused only to order disclosure of quality assurance review activities, plans for correction of deficiencies, and the opinions of persons leading to the corrective plans, based on the confidentiality exemptions of Public Health Law §§ 2805-j and 2905-m.

The Appellate Division unanimously affirmed, and further held that Defendant had failed to demonstrate any harm that might attach to any of the parties by allowing redisclosure to Plaintiff. The Court of Appeals granted Defendants leave to appeal from the Appellate Division order. The Court of Appeals affirmed.

The Court stated that the purpose of Public Health Law § 18(6) is to grant patients a right of access to their medical records subject to some limitations, and to prevent disclosure of confidential medical records to third parties.