Jazzlin Seiber v. Officer A. Smith - § 1983 Medical Disclosure Dismissed
Summary
The US District Court for the Western District of Virginia dismissed plaintiff Jazzlin Seiber's 42 U.S.C. § 1983 civil rights complaint against Officer A. Smith on April 24, 2026. Seiber alleged that the defendant disclosed her medical history to others at the jail where she is incarcerated. The court held that neither HIPAA nor the Constitution provides a private right of action for the disclosure of prisoner medical records, and dismissed the complaint without prejudice under 28 U.S.C. § 1915A(b)(1).
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What changed
The court dismissed Seiber's § 1983 complaint for failure to state a claim upon which relief may be granted under 28 U.S.C. § 1915A(b)(1). Seiber argued her medical information was wrongfully disclosed, but the court found no cognizable legal basis: HIPAA does not provide a private right of action, and no constitutional right to privacy in prisoner medical records has been recognized in the Fourth Circuit. The court noted in a footnote that disclosure solely for the purpose of humiliating a prisoner could potentially support an Eighth Amendment claim, but Seiber failed to plead sufficient facts to trigger that analysis.
Other parties with similar concerns should note that this ruling reinforces that HIPAA cannot be used as a standalone basis for civil litigation against state actors, and constitutional privacy claims by prisoners face a high bar. Prisons and jail staff are not subject to private suits under HIPAA itself, though they remain subject to OCR enforcement and potential Eighth Amendment claims under different factual predicates.
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Apr 27, 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 24, 2026 Get Citation Alerts Download PDF Add Note
Jazzlin Seiber v. Officer A. Smith
District Court, W.D. Virginia
- Citations: None known
- Docket Number: 7:25-cv-00043
Precedential Status: Unknown Status
Trial Court Document
CLERKS OFFICE US DISTRICT COURT
AT ROANOKE, VA
FILED
IN THE UNITED STATES DISTRICT COURT April 24, 2026
FOR THE WESTERN DISTRICT OF VIRGINIA LAURA A. AUSTIN, CLERK
ROANOKE DIVISION By: /s/ M. Poff
DEPUTY CLERK
JAZZLIN SEIBER, )
Plaintiff, )
)
V. ) Civil Action No. 7:25-cv-00043
)
OFFICER A. SMITH, ) By: Robert S. Ballou
Defendant. ) United States District Judge
MEMORANDUM OPINION
Plaintiff Jazzlin Seiber, a Virginia inmate proceeding pro se, has filed a civil rights action
pursuant to 42 U.S.C. § 1983, alleging that Defendant Officer A. Smith disclosed Seiber’s
medical history to others at the jail where she is incarcerated. Following the required review of
the Complaint pursuant to 28 U.S.C. § 1915A, I will dismiss the Complaint for failing to state a
claim upon which relief may be granted.
“Section 1983 imposes liability on state actors who cause the ‘deprivation of any rights,
privileges, or immunities secured by the Constitution.’” Doe v. Rosa, 795 F.3d 429, 436 (4th Cir.
2015). However, the court must dismiss any action filed by a prisoner against a governmental
entity or officer if the court determines the claims are frivolous, malicious, or fail to state a claim
upon which relief may be granted. 28 U.S.C. § 1915A(b)(1). The plaintiff's “[flactual allegations
must be enough to raise a right to relief above the speculative level,” to one that is “plausible on
its face,” rather than merely “conceivable.” Be// Atl. Corp v. Twombly, 550 U.S. 544, 555, 570 (2007).
Although Seiber is unclear about the source of her claim, she could have meant to bring it
under two independent sources: (1) the Health Insurance Portability and Accountability Act of
1996 (HIPAA) or (11) pursuant to § 1983. But under either source, Seiber’s claim is non-
cognizable. First, although HIPAA “prohibits the wrongful disclosure of . . . individually
identifiable health information[,] . . . the statute does not . . . provide a private right of action for
any citizen.” Burkey v. Balt. Cnty., No. GJH-20-2006, 2021 WL 3857814, at *11 (D. Md. Aug.
30, 2021) Second, “neither the U.S. Supreme Court nor the Fourth Circuit has even recognized a
constitutional right in the privacy of prisoners’ medical records.” Mallory v. Dorchester Cnty.
Det. Ctr., No. 2:23-cv-01688, 2024 WL 2159789, at *8 (D.S.C. Apr. 24, 2024) (quoting Van
Higgins v. Miller, No. 1:12-cv-00297, 2012 WL 4511524, at *2 (W.D.N.C. Oct. 1, 2012)), report
and recommendation adopted, 2024 WL 2155211 (D.S.C. May 14, 2024); see also Gamble v.
Simmons, No. 5:20-cv-03618, 2020 WL 7706621, at *2 (D.S.C. Dec. 29, 2020) (“[T]here is no
fundamental right of privacy in personal medical information.”).1 In the apparent absence of any
avenue to bring it, Seiber’s claim fails as a matter of law.
For these reasons, I will dismiss this action without prejudice under 28 U.S.C.
§ 1915A(b)(1) for failure to state a claim upon which relief may be granted. An appropriate order
accompanies this memorandum opinion.
Enter: April 24, 2026
//s/ Robert S. Ballou
Robert S. Ballou
United States District Judge
1 Some courts have recognized that the “disclosure of sensitive medical information may nevertheless
give rise to an Eighth Amendment claim, if, for example, it was done solely for the purpose of
humiliating the inmate.” Shields v. Dane Cnty. Jail Mental Health Dep’t, No. 17-cv-266, 2018 WL
5307807, at *2 (W.D. Wisc. Oct. 26, 2018) (citing Anderson v. Romero, 72 F.3d 518, 523 (7th Cir.
1995)). But even if Seiber could assert such a claim, she has failed to plead any facts to support it.
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