stating that the exemption in the Iowa Freedom of Information Act for "hospital records" and "medical records" of a "patient or former patient, including outpatient," did not apply to "county home" records in possession of the Governor's Office because the documents, which addressed the involuntary sterilization of the plaintiff, were neither compiled for diagnosis or treatment purposes by hospital or medical personnel nor maintained as records of a hospital or physician
How later courts described this case
- stating that the exemption in the Iowa Freedom of Information Act for "hospital records" and "medical records" of a "patient or former patient, including outpatient," did not apply to "county home" records in possession of the Governor's Office because the documents, which addressed the involuntary sterilization of the plaintiff, were neither compiled for diagnosis or treatment purposes by hospital or medical personnel nor maintained as records of a hospital or physician
- interpreting "medical records" as "documents . . . compiled for diagnostic or treatment purposes by hospital or medical personnel [or] maintained as records of a hospital or physician" (citations omitted)
- no liability in invasion of privacy action for disclosures of matters of public record which are of legitimate public concern
- judgment may be affirmed on grounds rejected by the trial court as well as on the ground accepted
Written by the judges who cited it.
The opinion
UHLENHOPP, Justice
(concurring specially).
I concur in division II of the majority opinion and in the result. I am influenced by a desire not to chill First Amendment rights by a restricted application of newsworthiness.
On the other hand, I would not reach the subject of division I. That division involves the issue of what constitutes a public record for purposes of the tort of violating a person’s privacy. I would await an appeal which actually necessitates a decision on that subject. Involved inter alia is the question whether unsolicited letters written to public officials automatically become public records for purposes of the tort although the letters deal with private affairs which would otherwise be protected by tort law. The privacy of members of the public may hang upon a very slender thread, depending upon our conclusion on this subject.