Greg Hale, et al v. ARcare, Inc
Split Score
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Case Summary
Disposition
Affirmed
The Eighth Circuit held that ARcare, a federally funded community health center, is not entitled to absolute immunity under the Federally Supported Health Centers Assistance Act for claims stemming from a 2022 data breach that exposed patients' confidential information. Affirming the district court, the panel adopted the Fourth Circuit’s narrow reading of 42 U.S.C. § 233(a), concluding that data security is not a 'medical, surgical, dental, or related function' and therefore the United States cannot be substituted as the defendant under the Federal Tort Claims Act.
Circuit Split Identified
Legal Issue
Whether the absolute immunity granted under 42 U.S.C. § 233(a) to federally funded community health centers for damages 'resulting from the performance of medical, surgical, dental, or related functions' extends to claims arising from a data breach and failure to safeguard confidential patient information.
Circuit Positions
§ 233(a) immunity covers data security; a data breach is a 'related function' to providing medical services.
§ 233(a) immunity does not cover data security; data-breach claims are outside the scope of 'related functions.'
Conflict Summary
The Ninth Circuit (and some district courts) interpret 'related functions' broadly, holding that data-security obligations are sufficiently connected to the practice of medicine to trigger § 233(a) immunity, while the Fourth Circuit—and now the Eighth Circuit—read the term narrowly, limiting immunity to activities directly tied to providing health-care treatment and therefore denying immunity for data-breach claims.