New York Court Finds Clinic Not Liable for Employee's Disclosure of PHI

I can picture a lot of lawyers breathing a sigh of relief over this one. Robyn Sterling writes:

A federal district court dismissed an action against an employer alleging vicarious liability for an employee’s dissemination of a patient’s protected health information (PHI) related to treatment for a sexually transmitted disease (STD). Specifically, the court found that the employer, a private New York medical clinic, was not vicariously liable for the actions of the employee because the employee was acting in a personal capacity which was beyond the scope of her employment.