James W. Boyer v. Brady Thomas and Z. Shifflett
Summary
James W. Boyer, a pro se prisoner plaintiff, filed suit in the Northern District of Indiana alleging that Urgent Care and the Auburn City Police Department violated the Health Insurance Portability and Accountability Act by improperly disclosing his medical records. The court dismissed the complaint under 28 U.S.C. § 1915A because Boyer failed to state a claim upon which relief may be granted, having sued Sheriff Brady Thomas and Deputy Z. Shifflett without alleging their personal involvement in any HIPAA violation. The court further held that amendment would be futile because HIPAA confers no private right of action on individual plaintiffs.
“HIPAA prohibits the disclosure of medical records without the patient's consent.”
Healthcare providers and their legal counsel should be aware that while HIPAA prohibits unauthorized disclosure of medical records and imposes obligations on covered entities, the statute does not create a private right of action that patients can enforce through litigation. Inmate and prisoner plaintiffs attempting to bring HIPAA-based claims will likely face dismissal on the same grounds, as federal courts consistently hold that HHS is the sole enforcement authority.
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What changed
The court dismissed the prisoner's complaint under 28 U.S.C. § 1915A for failure to state a claim. Boyer named Sheriff Brady Thomas and Deputy Z. Shifflett as defendants but did not allege they personally participated in any HIPAA violation. He also declined to sue Urgent Care and the Auburn City Police Department—the entities he claimed actually disclosed his records improperly. The court held that HIPAA confers no private right of action and that enforcement rests with the Department of Health and Human Services, not private plaintiffs. The court exercised its broad discretion to deny leave to amend, finding amendment would be futile. Affected parties should note that individuals cannot bring private lawsuits under HIPAA for unauthorized disclosure of medical records; only HHS may enforce the statute.
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Apr 25, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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April 6, 2026 Get Citation Alerts Download PDF Add Note
James W. Boyer v. Brady Thomas and Z. Shifflett
District Court, N.D. Indiana
- Citations: None known
- Docket Number: 1:26-cv-00139
Precedential Status: Unknown Status
Trial Court Document
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA
FORT WAYNE DIVISION
JAMES W. BOYER,
Plaintiff,
v. No. 1:26 CV 139
BRADY THOMAS, and Z. SHIFFLETT,
Defendants.
OPINION and ORDER
James W. Boyer, a prisoner without a lawyer, filed a complaint alleging Urgent
Care and the Auburn City Police Department violated the Health Insurance Portability
and Accountability Act (HIPPA) with his medical records. (DE # 1.) “A document filed
pro se is to be liberally construed, and a pro se complaint, however inartfully pleaded,
must be held to less stringent standards than formal pleadings drafted by lawyers.”
Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quotation marks and citations omitted).
Nevertheless, under 28 U.S.C. § 1915A, the court must review the merits of a prisoner
complaint and dismiss it if the action is frivolous or malicious, fails to state a claim upon
which relief may be granted, or seeks monetary relief against a defendant who is
immune from such relief.
Boyer sues Sheriff Brady Thomas and Deputy Z. Shifflett, but he does not allege
they were involved in the HIPPA violation. He does not sue Urgent Care and the
Auburn City Police Department even though he alleges they violated HIPPA. “HIPAA
prohibits the disclosure of medical records without the patient’s consent. See 42 U.S.C.
§§ 1320d–1 to d–7. However, without regard to whom he named as a defendant
“HIPPA confers no private right of action.” Stewart v. Parkview Hosp., [940 F.3d 1013,
1015](https://www.courtlistener.com/opinion/4671766/tyquan-stewart-v-parkview-hospital/#1015) (7th Cir. 2019). Medical professionals are “bound by the statute’s disclosure
prohibitions and confidentiality requirements,” but the enforcement for violations is the
job of the Department of Health and Human Services and not private plaintiffs. Id. This complaint does not state a claim. “The usual standard in civil cases is to
allow defective pleadings to be corrected, especially in early stages, at least where
amendment would not be futile.” Abu-Shawish v. United States, 898 F.3d 726, 738 (7th
Cir. 2018). “District courts, however, have broad discretion to deny leave to amend a
complaint where the amendment would be futile.” Russell v. Zimmer, Inc., 82 F.4th 564,
572 (7th Cir. 2023). For the reasons explained, such is the case here.
For these reasons, this case is DISMISSED under 28 U.S.C. § 1915A.
SO ORDERED.
Date: April 6, 2026
s/James T. Moody
JUDGE JAMES T. MOODY
UNITED STATES DISTRICT COURT
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