Requiring Intent to Harm for Record-Sharing Breach Is Error
Div. Three of the Fourth District Court of Appeal has held that a trial judge erred in granting a motion for partial judgment notwithstanding the verdict as to the willful intent element required for an award of treble damages in a case asserting a claim against an Orange County Sheriff’s Department employee who shared the plaintiff’s mental health records relating to a temporary involuntary commitment with the patient’s sister.
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