Lawson v. Meconi

Summary

The Supreme Court of Delaware reviewed an interlocutory appeal concerning whether government officials could publicly disclose information from an autopsy, toxicology report, death certificate, and related examination records. The court held that Delaware's Medical Examiners Statute and Health Record Privacy Statute prohibited public disclosure of the autopsy information under the circumstances, reversed the Court of Chancery, and remanded for entry of a permanent injunction. The court did not decide the asserted common-law privacy claim.

Holdings

1. Autopsy information gathered and disclosed by a medical examiner to a police department on a confidential basis during an investigation into the medical cause of death remains confidential and may not be disclosed to the public.
2. Under the circumstances of Duane Lawson's death, Delaware's Health Record Privacy Statute prohibited the defendants from publicly disclosing any protected health information contained in the autopsy information.
3. Because the Delaware statutes provided the requested privacy protection, the court did not need to decide the claim for injunctive relief based on a common-law right of privacy.

Questions Presented

1. Whether Delaware's Medical Examiners Statute prohibited public disclosure of autopsy information that a medical examiner shared confidentially with a police department during a death investigation.
2. Whether Delaware's Health Record Privacy Statute prohibited public disclosure of protected health information contained in an autopsy report, death certificate, toxicology report, or related examination record.
3. Whether the Court needed to decide whether Delaware recognized a common-law privacy right for a decedent or the decedent's family.

Disposition

reversed_and_remanded