Hospital Admission and Room Numbers Are Health Records Under Minnesota Law

1. Introduction

The Minnesota Supreme Court held that information identifying someone as a patient at a particular hospital and in a particular room is a “health record” under the Minnesota Health Records Act. Protection does not depend on whether the disclosure reveals a diagnosis, treatment plan, or other traditionally clinical information.

The dispute arose after an Allina Health System employee disclosed Justin Holtzbauer’s hospitalization and room number to his former spouse, despite his decision to opt out of the hospital’s facility directory. Allina argued that this information was merely nonclinical identifying information, outside the Act’s definition of a health record. Holtzbauer maintained that it related directly to the provision of health care and therefore fell within the statutory definition.

The court accepted Holtzbauer’s interpretation as the only reasonable reading of the statute. Its decision establishes an important boundary for health-information disclosure: administrative or identifying information can be protected health information even when it reveals no particular medical condition.

2. Background and Procedural History

The disclosure

On November 26, 2022, Holtzbauer suffered a chest injury while working as a tree trimmer. After his pain worsened, he sought treatment at Mercy Hospital, an Allina facility. Upon admission, he opted out of the facility directory. Allina omitted him from that directory and marked his file as a “confidential encounter.”

Holtzbauer told his former spouse, H.H., by text that he was injured and hospitalized. When he did not immediately respond to a later request for his location, she began calling hospitals. Mercy initially denied that he was a patient. An employee at United Hospital, another Allina facility, subsequently disclosed that Holtzbauer was at Mercy and supplied his room number.

Allina later acknowledged that the disclosure should not have occurred because Holtzbauer had opted out of the directory. The parties stipulated that the disclosure violated Allina’s Patient Privacy Rights Policy and that Allina would be vicariously liable if Holtzbauer established breach and causation under the Act.

The litigation

Holtzbauer sued for compensatory damages under the Minnesota Health Records Act. Allina sought summary judgment, principally arguing that hospital admission and room-location information were not health records.

The district court agreed with Allina. It reasoned that the information did not explicitly reveal Holtzbauer’s care or condition, particularly because Mercy provided treatment for many different conditions. A divided court of appeals reversed, concluding that the information related to the provision of health care.

The Supreme Court affirmed the court of appeals and remanded for further proceedings. Justices Hennesy and Aligada, Jr., did not participate. The supplied Supreme Court opinion contains no dissent.

3. Summary of the Opinion

The court’s central holding rests on the statutory definition:

“Health record” means any information, whether oral or recorded in any form or medium, that relates to the past, present, or future physical or mental health or condition of a patient; the provision of health care to a patient; or the past, present, or future payment for the provision of health care to a patient.

The court reached four principal conclusions:

1. Admission and room information qualify. They have a connection, association, or logical relationship to providing health care.
2. Health records are not limited to clinical information. The statute contains no such limitation.
3. Identifying information is not a mutually exclusive category. Within the Act’s structure, identifying information is a subset of health-record information, not an unprotected alternative to it.
4. Allina’s disclosure violated the Act. Nevertheless, Holtzbauer must still prove injury caused by the disclosure and establish the amount of damages.

The ruling therefore resolves the statutory classification and disclosure questions, but it does not award damages or decide causation.

4. The Governing Statutory Framework

Minnesota’s consent-based framework

Under Minnesota Statutes § 144.293, subdivision 2, a provider generally may not release a patient’s health records without:

• A signed and dated consent from the patient or a legally authorized representative;
• Specific authorization in Minnesota law; or
• A representation from another provider that it holds the required signed and dated consent.

The Act also contains more specific disclosure provisions and exceptions. These address matters including disclosures to the commissioner of health, certain necessary disclosures, mental-health information, and exchanges through record locator or patient information services. The court treated this structure as a deliberate legislative balance: a protective general rule accompanied by defined exceptions.

Minnesota Statutes § 144.298, subdivision 2, provides a private remedy for negligent or intentional requests for or releases of health records in violation of the specified provisions. Thus, statutory protection is backed by an individual damages action, subject to the applicable requirements of that action.

HIPAA’s related but distinct role

HIPAA’s definition of “health information” is virtually identical to Minnesota’s definition of “health record.” Its Privacy Rule permits certain facility-directory disclosures after notice and an opportunity for the patient to restrict or prohibit them. Directory information may include a patient’s name, location, general condition, and religious affiliation, although religious affiliation may be disclosed only to clergy.

HIPAA does not generally displace state privacy provisions that are more stringent. Accordingly, federal permission to disclose information does not necessarily establish permission under Minnesota law.

The court also noted Minnesota’s 2024 enactment directing that the Act protect privacy more stringently than the relevant federal rules. Because that enactment followed the 2022 disclosure, it was not the original source of the obligations at issue. The court described it as reflecting the preexisting federal recognition of more protective state law.

Finally, HIPAA does not itself provide the private damages action Holtzbauer pursued. His claim arose under Minnesota’s statute, not directly under HIPAA.

5. Analysis of the Court’s Legal Reasoning

A. “Any information” signals breadth

The court began with the Legislature’s chosen definition rather than an ordinary, narrower understanding of a medical chart. “Information” encompasses facts learned or supplied about a person or subject. The modifier “any” makes the definition inclusive rather than restrictive.

The express inclusion of oral information is also important. A protected health record need not be a document, electronic chart entry, or diagnostic report. An employee’s spoken disclosure can fall within the Act.

This does not mean that the court definitively classified every fact a hospital possesses as a health record. It rejected Allina’s assertion that such breadth necessarily made Holtzbauer’s interpretation unreasonable, without needing to settle the protection of every conceivable category of information.

B. “Relates to” requires a connection, not disclosure of a diagnosis

The decisive statutory relationship was between the disclosed information and “the provision of health care to a patient.” Applying its established interpretation of “relating to,” the court asked whether the information had a connection, association, or logical relationship to providing health care.

Hospital admission and room assignment satisfy that test. They communicate that the person is receiving care at a particular place. The court also observed that admission may convey information about the potential severity or urgency of care.

The oncology-unit example illustrated an additional privacy concern: location can reveal or suggest the nature of treatment. But the holding did not depend on that possibility. Information about a patient’s admission to a general hospital also falls within the definition. No specialty-unit inference or identifiable diagnosis is required.

C. Related provisions confirm that admission information is protected

The court found contextual support in Minnesota Statutes § 144.294, subdivision 3, which permits specified mental-health information to be released to family members under particular circumstances.

That provision expressly includes “admission to or discharge from treatment” among the health-record information potentially subject to authorized disclosure. Because the provision creates an exception to the ordinary disclosure rules, it supports the conclusion that admission information belongs within the protected category in the first place.

This was textual and structural analysis, not a finding that the statute was ambiguous followed by resort to broad policy preferences.

D. “Identifying information” is a subset, not an exclusion

Allina relied heavily on the Act’s separate definition of “identifying information,” which includes names, addresses, birth dates, and other nonclinical data that uniquely identify a patient. It argued that separate definitions established separate, non-overlapping categories.

The court rejected that inference by examining what the definition actually does. “Identifying information” appears in the Act’s provision concerning record locator and patient information services. These services help providers locate records held elsewhere; they do not themselves hold the underlying clinical documents.

Section 144.293, subdivision 8, permits specified identifying and record-location information to be shared with those services without affirmative consent, unless the patient opts out. This arrangement operates as a limited exception to the general consent requirement.

If identifying information were outside health records altogether, an exception governing its release would be unnecessary. Allina’s alternative explanation—that subdivision 8 independently and implicitly made identifying information private—required a strained reading that the court declined to adopt.

The distinction between the services discussed in subdivision 8 and a hospital’s public-facing facility directory remains important. The court used their disclosure structures to illuminate statutory meaning; it did not treat them as interchangeable systems.

E. Overlapping categories do not justify a clinical-only limitation

Allina argued that a broad reading of information relating to health-care provision would swallow the definition’s other categories: information about health or condition and information about payment. It invoked the interpretive preference against treating statutory language as redundant.

The court answered that statutory categories can overlap. Legislatures sometimes use a “belt-and-suspenders” approach, providing multiple routes to the same protective result. Avoiding overlap is not an absolute rule that overrides the text.

More fundamentally, Allina’s proposed solution had no textual foundation. Nothing in the definition restricts health records to “clinical information.” The narrowing argument also conflicted with the breadth signaled by “any” and “relates to.”

F. Other statutory wording did not create the proposed limitation

Allina pointed to the patient-access provision referring to “health records and other information about the patient.” The court explained that this wording predated the 2007 adoption of a statutory definition of health record. Its transfer into the recodified Act revealed little about the boundaries of that newly defined term.

Allina’s arguments based on “health care” and “patient” likewise failed. Even accepting its proposed definition of health care as efforts to maintain, restore, or promote well-being, hospital admission and room information remain connected to those efforts. The definition of “patient” identifies the people covered; it does not silently restrict protected information to treatment details.

G. Policy concerns belong within the legislative framework

The court acknowledged practical concerns involving law enforcement, family communications, spiritual care, hospital operations, and litigation. It also recognized the dangers of unauthorized disclosures, including risks to people who have experienced domestic violence.

Rather than choose a preferred policy balance, the court enforced the statutory balance already enacted. Additional exceptions or limitations on private remedies, it concluded, are matters for legislative consideration.

6. Precedents Cited and Their Influence

A. Decisions most directly shaping the substantive interpretation

500, LLC v. City of Minneapolis, 837 N.W.2d 287 (Minn. 2013)

This was the principal analogy for interpreting “relates to.” A property owner sought approval affecting a proposed historic property. The question was whether the application was a written request “relating to zoning,” triggering a statutory decision deadline and approval by operation of law.

The court rejected a limitation to requests explicitly arising under zoning provisions. Instead, a request related to zoning if it had a connection, association, or logical relationship to regulating building development or property use. Historic-preservation approval met that standard because of its effects on property use and its links to the zoning framework.

In Holtzbauer’s case, the same interpretive approach defeated the argument that only explicitly clinical information qualifies. Hospital admission and location need not themselves describe treatment; their relationship to providing care is sufficient.

Morales v. Trans World Airlines, Inc., 504 U.S. 374 (1992)

The opinion cited this decision through 500, LLC v. City of Minneapolis as the source of the broad formulation of “relating to”: standing in a relation to, having a bearing on, or being associated or connected with something. Its role was definitional rather than a direct analogy involving patient privacy.

Phone Recovery Services, LLC v. Qwest Corp., 919 N.W.2d 315 (Minn. 2018)

This case interpreted the Minnesota False Claims Act’s exclusion for statutory provisions “relating to taxation.” A private plaintiff sought recovery of uncollected telecommunications-related charges. After determining that the charges were taxes, the court held the action barred.

The decision reinforced the broad meaning of “relating to.” It also supplied an alternative analysis: even if the phrase meant the narrower word “about,” the result would be unchanged. Here, information that someone has been admitted to a hospital room is still “about” the provision of care. This made the holding less dependent on choosing the broadest possible phrasing.

Furlow v. Madonna Summit of Byron, No. A19-987, 2020 WL 413356 (Minn. App. Jan. 27, 2020)

The district court relied on this nonprecedential decision when concluding that information not explicitly revealing care or condition fell outside the Act. The Supreme Court rejected the clinical-information limitation underlying that approach.

The opinion did not expressly announce that it was overruling this nonprecedential decision. Nevertheless, reasoning that excludes admission and room information simply because it does not reveal a specific condition cannot be reconciled with the Supreme Court’s holding.

Holtzbauer v. Allina Health Sys., 23 N.W.3d 608 (Minn. App. 2025)

The court of appeals majority held that admission and room information fell within the statutory text. Its dissent considered that interpretation too broad and inconsistent with the Act’s context. The Supreme Court affirmed the majority’s result and independently explained why the broader interpretation was the only reasonable one.

B. Authorities governing statutory interpretation

• Schneider v. Child.'s Health Care, 996 N.W.2d 197 (Minn. 2023), supplied the de novo standard of review. The Supreme Court therefore resolved statutory meaning independently rather than deferring to the district court.

• State v. Fugalli, 967 N.W.2d 74 (Minn. 2021), established that an enacted statutory definition controls. It also supported considering contemporaneously enacted provisions addressing the same subject and rejecting interpretations that unduly strain ordinary language. These principles supported both the broad definition and the use of the mental-health disclosure provision as context.

• In re SIRS Appeal by Best Care, LLC, 26 N.W.3d 459 (Minn. 2025), provided the controlling plain-meaning framework: when text and context yield only one reasonable interpretation, that meaning governs. Competing party submissions do not themselves establish ambiguity.

• Douglas v. State, 986 N.W.2d 705 (Minn. 2023), authorized consultation of dictionaries for undefined terms. State v. Gorman, 546 N.W.2d 5 (Minn. 1996), supported looking to earlier judicial interpretations. Together, they explained the court’s use of ordinary definitions and established case law.

• In re Est. of Ecklund, 20 N.W.3d 351 (Minn. 2025), supported evaluating whether competing interpretations are reasonable, recognizing the significance of absent limiting language, and consulting sufficiently similar federal law before finding ambiguity. These principles undermined the proposed clinical-only restriction and supported consideration of HIPAA.

• Buzzell v. Walz, 974 N.W.2d 256 (Minn. 2022), supported rejecting interpretations that stretch statutory text too far. It reinforced the rejection of Allina’s theory that the record-locator provision implicitly created an independent privacy rule for otherwise unprotected identifying information.

C. Authorities supporting the inclusive meaning of “any”

• In re Welfare of Child of B.D.D., 25 N.W.3d 707 (Minn. 2025), supplied the court’s most comprehensive recent explanation that “any” expresses inclusion and, when used affirmatively, generally means every or all. This directly strengthened the reading of “any information.”

• Berrier v. Minn. State Patrol, 9 N.W.3d 368 (Minn. 2024), illustrated that “any potential dog owner” included the Minnesota State Patrol, demonstrating the breadth produced by the modifier.

• In re PERA Police & Fire Plan Line of Duty Disability Benefits of Brittain, 724 N.W.2d 512 (Minn. 2006), treated “any act of duty” as intentionally inclusive rather than restrictive.

• Hyatt v. Anoka Police Dep't, 691 N.W.2d 824 (Minn. 2005), applied a broadly worded dog-owner definition to a municipal owner of a police dog. Like the other examples, it showed that courts should not introduce unstated exclusions into inclusive statutory language.

D. Authorities permitting overlapping statutory protections

In re Welfare of A.J.B., 929 N.W.2d 840 (Minn. 2019), discussed a legislative belt-and-suspenders approach to a criminal offense’s mental-state requirements. The court used it to explain why overlapping language is not automatically meaningless.

The opinion also cited Justice Thissen’s concurrence in G&I IX OIC LLC v. County of Hennepin, 979 N.W.2d 52 (Minn. 2022), for the observation that courts do not demand absolute freedom from redundancy in every statute. The cited passage was a concurrence, not a separate majority holding. Its role here was to reinforce the explanation that the anti-redundancy principle is not mechanical.

E. Authorities concerning analogous federal law and institutional roles

Henry v. Indep. Sch. Dist. #625, 988 N.W.2d 868 (Minn. 2023), explained that analogous federal decisions may inform interpretation of similar Minnesota statutes without binding the Minnesota court. Although that case concerned the Minnesota Human Rights Act, its methodological point helped explain the use of HIPAA as contextual support.

State v. Khalil, 956 N.W.2d 627 (Minn. 2021), framed the court’s treatment of policy objections. It emphasized legislative institutional competence to resolve competing interests and the Legislature’s authority to amend a statute after judicial interpretation. The precedent supported enforcing the enacted language rather than creating judicial exceptions for difficult operational situations.

F. Federal decisions establishing that HIPAA has no private cause of action

The opinion cited the following decisions for the shared proposition that individuals cannot sue directly under HIPAA’s Privacy Rule:

• Acara v. Banks, 470 F.3d 569 (5th Cir. 2006).
• Webb v. Smart Document Sols., LLC, 499 F.3d 1078 (9th Cir. 2007).
• Miller v. Nichols, 586 F.3d 53 (1st Cir. 2009).
• Wilkerson v. Shinseki, 606 F.3d 1256 (10th Cir. 2010).
• Dodd v. Jones, 623 F.3d 563 (8th Cir. 2010).
• Stewart v. Parkview Hosp., 940 F.3d 1013 (7th Cir. 2019).
• Meadows v. United Servs., Inc., 963 F.3d 240 (2d Cir. 2020).
• Payne v. Taslimi, 998 F.3d 648 (4th Cir. 2021).

These authorities did not determine what Minnesota classifies as a health record. Their importance was remedial: they explained why Allina’s acknowledged HIPAA violation did not itself supply Holtzbauer’s lawsuit, while Minnesota’s express private remedy did.

7. Potential Impact

Provider practices and information systems

Hospitals cannot safely classify patient status and room information as outside the Act merely because they are administrative or nonclinical. Compliance practices must account for disclosures through switchboards, reception desks, interfacility systems, and other channels beyond the formal medical chart.

The facts particularly illustrate the need for confidentiality preferences to function across an integrated health system. Mercy initially withheld the information, but an employee at another Allina hospital disclosed it.

Future litigation

The decision removes a threshold obstacle to claims involving unauthorized disclosures of hospitalization and location. Plaintiffs need not show that the information disclosed a diagnosis before it can qualify as a health record.

It does not, however, make compensation automatic. The statutory remedy addresses negligent or intentional violations, and Holtzbauer must still establish causation, injury, and damages. An internal-policy violation, statutory protection, and a recoverable damages claim remain analytically distinct matters.

Consent and statutory exceptions

The classification question is now settled for the information at issue. Whether a particular disclosure is lawful still requires examination of consent and applicable legal authorization.

The opinion should not be read as deciding every possible directory disclosure or creating an absolute prohibition on hospital communications. Nor does it establish that compliance with HIPAA’s directory rules invariably satisfies Minnesota law. Providers must assess the state framework independently.

Privacy, safety, and legislative responsibility

The ruling strengthens protection for patients whose whereabouts may themselves be sensitive. At the same time, it may complicate communications with families, clergy, and public-safety personnel. The court expressly left any additional exceptions or targeted limitations on private remedies to the Legislature.

8. Complex Concepts Simplified

Health record

Under this Act, protected information is broader than a medical chart. It can include spoken information about where someone is receiving care.

Clinical and nonclinical information

Clinical information concerns matters such as diagnosis and treatment. Nonclinical information includes identifying or administrative details. The court held that this distinction does not itself determine statutory protection.

De novo review

The appellate court decides the legal question independently, without deferring to the lower court’s interpretation.

Summary judgment

A decision without trial when the governing law and relevant undisputed facts permit it. Here, Allina’s proposed legal basis for judgment failed.

Plain meaning and ambiguity

A statute is not ambiguous simply because the parties disagree. Ambiguity requires more than one reasonable interpretation after considering text and context.

The superfluity canon

A preference for giving statutory words independent work. It does not forbid all overlap between statutory categories.

Preemption

Federal law can displace conflicting state law. HIPAA preserves qualifying state privacy rules that provide stronger protection.

Private right of action

Legal authority for an individual to sue. Minnesota’s Act provides such authority; HIPAA itself does not.

Vicarious liability

Responsibility imposed on one party for another’s conduct, such as an employer’s responsibility for an employee. Allina’s relevant responsibility was addressed by the parties’ conditional stipulation.

Causation

The required connection between wrongful disclosure and a claimed injury. Establishing an unlawful disclosure does not, by itself, prove compensable harm.

9. Conclusion

Information that a person is a hospital patient in a particular room is a health record under Minnesota law, even without disclosure of a diagnosis or treatment. The court reached that conclusion through the statute’s expansive language, its disclosure structure, and supporting federal context.

The decision rejects a clinical-only boundary for health-record protection while preserving the distinction between an unlawful disclosure and proven damages. Its broader significance lies in recognizing that the circumstances and location of receiving care can themselves be protected medical information.