STATE OF MINNESOTA
IN SUPREME COURT
A24-1390
Court of Appeals Justin Holtzbauer, Respondent,
vs.
Allina Health System, Appellant.
Thissen, J.
Took no part, Hennesy, Aligada, Jr., JJ. Filed: November 4, 2026
Office of Appellate Courts
________________________
Christopher Kuhlmann, Kuhlmann Law, LLC, Minneapolis, Minnesota; and Samuel Savage, Savage-Westrick, P.L.L.P., Bloomington, Minnesota, for respondent. Mark R. Bradford, Elizabeth A. Euller, Bradford Andresen Norrie & Camarotto, Bloomington, Minnesota, for appellant.
Daniel R. Kelly, Brandon J. Wheeler, Alec R. Rolain, Felhaber Larson, Minneapolis, Minnesota, for amici curiae Law Enforcement Labor Services, Inc. and Legal Defense Fund of the Peace Officers Research Association of California. Taylor Brandt Cunningham, Bolt Law Firm, Anoka, Minnesota; and Jennifer E. Olson, TSR Injury Law, Bloomington, Minnesota, for amicus curiae Minnesota Association for Justice.
David W. Asp, Derek C. Waller, Lockridge Grindal Nauen PLLP, Minneapolis, Minnesota, for amicus curiae Minnesota Hospital Association. ________________________
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S Y L L A B U S
Information that a person is a patient at a hospital in a particular room is a health record as defined in the Minnesota Health Records Act, Minnesota Statutes section 144.291, subdivision 2(c).
Affirmed.
O P I N I O N
THISSEN, Justice. Mercy Hospital (Mercy) is part of appellant Allina Health System (Allina). Respondent Justin Holtzbauer, a patient at Mercy, opted out of the facility's directory upon admission. Accordingly, Allina did not list Holtzbauer in the facility directory and marked his file as a "confidential encounter" to indicate his status to Allina staff. Later, an Allina employee informed Holtzbauer's former spouse, H.H., that Holtzbauer was a patient at Mercy and provided his room number.
Holtzbauer sued Allina, arguing that the fact of his admission to the hospital and his room number constituted a "health record" as defined in the Minnesota Health Records Act (the Act). Minn. Stat. § 144.291, subd. 2(c). Holtzbauer also asserted that, by disclosing this health record, Allina violated the Act. Allina disagreed and moved for summary judgment. The district court granted Allina's motion for summary judgment. The court of appeals reversed. We granted Allina's petition for further review. We are asked to interpret the statutory definition of "health record" under the Act and determine whether Allina's disclosure of Holtzbauer's admission to Mercy and his room number violated the Act. We acknowledge that the question of whether, and the
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circumstances under which, a hospital should be able to disclose the fact that a patient has been admitted to a hospital and the patient's room number without the patient's consent implicate important public policy concerns related to nonconsensual disclosures of private medical information, law enforcement's communication with hospitals, and possible burdens on the court system. But our job in interpreting a statute is to ascertain what the Legislature intended when it enacted that statute. Based on these considerations, we conclude that admission and location information within a health care facility is a health record because it falls within the Act's definition of that term as including "any information … that relates to … the provision of health care to a patient." Minn. Stat. § 144.291, subd. 2(c). Consequently, we hold that Allina's disclosure of Holtzbauer's information violated the Act, and we affirm the decision of the court of appeals and remand to the district court for further proceedings consistent with this opinion. To the extent that our interpretation of the Act's definition of "health record" may unsettle current practices, resolving the broader complex and competing policy concerns rests with the Legislature, which is best positioned to resolve them. State v. Khalil,
956 N.W.2d 627, 633 (Minn. 2021) ("Our deference to the intention of the Legislature …. reflects a structural understanding that legislators are the elected representatives of the people and that legislative bodies are institutionally better positioned than courts to sort out conflicting interests and information surrounding complex public policy issues.").
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FACTS
Access to and disclosure of patient records are controlled by a combination of federal and state law. We therefore first discuss relevant federal and Minnesota law before turning to the facts of this case.
HIPAA Privacy Rule Thirty years ago, Congress enacted the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Pub. L. No. 104-191, 110 Stat. 1936. HIPAA defines "health information" as follows:
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 an individual, the provision of health care to an individual, or the past, present, or future payment for the provision of health care to an individual.
42 U.S.C. § 1320d(4). Certain administrative regulations promulgated under HIPAA constitute the HIPAA Privacy Rule.1Under the HIPAA Privacy Rule, a hospital "may use or disclose protected health information, provided that the individual is informed in advance of the use or disclosure and has the opportunity to agree to or prohibit or restrict the use or disclosure." 45 C.F.R. § 164.510 (2022).
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Among other things, the HIPAA Privacy Rule authorizes hospitals to maintain a facility directory containing certain protected health information—the individual's name,
"location in the … facility," "condition described in general terms that does not communicate specific medical information about the individual," and "religious affiliation"—and disclose such information to "members of the clergy; or … other persons who ask for the individual by name."245 C.F.R. § 164.510(a)(1). Specifically, a hospital
must inform an individual of the protected health information that it may include in a directory and the persons to whom it may disclose such information … and provide the individual with the opportunity to restrict or prohibit some or all of the uses or disclosures permitted by paragraph (a)(1) of this section.
45 C.F.R. § 164.510(a)(2). Under HIPAA, a hospital may also disclose protected health information in a facility directory under emergency circumstances. 45 C.F.R. § 164.510(a)(3).
The HIPAA Privacy Rule generally preempts any contrary provision of state law.
45 C.F.R. § 160.203 (2022). There is an exception, however, when "[t]he provision of State law relates to the privacy of individually identifiable health information and is more stringent than a standard, requirement, or implementation specification adopted under"
the HIPAA Privacy Rule. 45 C.F.R. § 160.203(b) (emphasis added). A state law that regulates "a use or disclosure" is more stringent if "the law prohibits or restricts a use or
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disclosure in circumstances under which such use or disclosure otherwise would be permitted under" the HIPAA Privacy Rule. 45 C.F.R. § 160.202 (2022).3 HIPAA does not create a private cause of action for an individual to enforce the HIPAA Privacy Rule.4Accordingly, when a hospital violates a patient's rights under HIPAA, the patient cannot directly sue the hospital based on that violation.
Minnesota Health Records Act The Legislature enacted the Minnesota Health Records Act in 2007. Act of May 25, 2007, ch. 147, art. 10, §§ 2-9, 2007 Minn. Laws 1804, 2098-2106 (codified as amended at Minn. Stat. §§ 144.291-.298). This legislation recodified several existing statutory provisions related to health records and added new provisions related to, among other things, sharing electronic medical records among providers. Most relevant to this
3 In 2024, after the events that gave rise to this case, the Minnesota Legislature amended the Act to specify that it "must be construed to protect the privacy of a patient's health records in a more stringent manner than provided in Code of Federal Regulations, title 45, part 164." Act of May 24, 2024, ch. 127, art. 66, § 7, 2024 Minn. Laws 2753,
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appeal, the Act replaced an earlier statute regulating access to health records,5defined the term "health record" for the first time, and bolstered the statutory framework governing accessing and using health records. Id.
Under the Act, "health record" is defined as follows:
"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. Minn. Stat. § 144.291, subd. 2(c). This language is virtually identical to HIPAA's definition of "health information." Compare Minn. Stat. § 144.291, subd. 2(c), with
42 U.S.C. § 1320d(4). The Legislature carefully structured the Act to balance patient privacy interests with other policy concerns. The parties generally agree that information that constitutes a
"health record" is private unless a patient consents to its disclosure or Minnesota law authorizes releasing the information without patient consent. Minnesota Statutes section 144.293, subdivision 1, specifies that "[h]ealth records can be released or disclosed as specified in subdivisions 2 to 9 and sections 144.294 and 144.295."
Section 144.293, subdivision 2, then sets forth a general rule: releasing a patient's health records is impermissible without "(1) a signed and dated consent from the patient or the patient's legally authorized representative authorizing the release; (2) specific
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authorization in Minnesota law; or (3) a representation from a provider that holds a signed and dated consent from the patient authorizing the release."
Other subdivisions of section 144.293 refine the general rule. For instance, subdivision 4 addresses the duration of a patient's consent, and subdivision 8 sets forth the circumstances under which health records may be released to record locator services and patient information services. Minn. Stat. § 144.293, subds. 4, 8. Other provisions of the Act provide exceptions to the consent requirement. One exception allows for releasing health records to the commissioner of health. Id., subd. 7. Other exceptions require necessity—circumstances where the subject of the health record is unable to give consent or the disclosure is necessary for the subject's health or safety, or the health or safety of others. Id., subd. 5; Minn. Stat. § 144.294, subds. 2-3. In addition to the definition of "health record," the Act separately defines
"identifying information" as "the patient's name, address, date of birth, gender, parent's or guardian's name regardless of the age of the patient, and other nonclinical data which can be used to uniquely identify a patient." Minn. Stat. § 144.291, subd. 2(d). As we shall see, one of the parties' basic disagreements is over whether "identifying information" is distinct from a "health record."
Finally, unlike HIPAA, the Legislature created a private right of action that allows a patient to sue a provider for damages and other relief when the provider violates the Act. Minn. Stat. § 144.298, subd. 2.
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Holtzbauer's Hospitalization and Allina's Disclosure On November 26, 2022, Holtzbauer was struck in the chest by a tree while working as a tree trimmer. Several hours later, Holtzbauer went to Allina's Mercy because he felt worsening chest pain. Holtzbauer was admitted to Mercy and opted out of Mercy's facility directory. Because he opted out of the directory, Holtzbauer's admission to Mercy and room number were made confidential and inaccessible to the public. Allina did not list Holtzbauer in the facility directory and marked his file as a "confidential encounter" to indicate his status to Allina staff.
After arriving at the hospital, Holtzbauer texted his ex-spouse, H.H., and told her that he was injured and hospitalized. Several hours later, H.H. texted Holtzbauer and asked for his location; Holtzbauer did not respond immediately. H.H. began calling local hospitals. At each hospital she contacted, H.H. would provide Holtzbauer's name and birth date and ask if he was a patient. H.H. called Mercy first and Mercy denied that Holtzbauer was a patient. H.H. called several more hospitals; each denied Holtzbauer was a patient. When H.H. called United Hospital, another Allina facility, an Allina employee informed H.H. that Holtzbauer was a patient at Mercy and provided his room number.6 Holtzbauer expressed concern to a patient representative at Mercy that his information had been disclosed without his consent. In a January 4, 2023 letter, Allina confirmed that an Allina employee had disclosed Holtzbauer's patient status, facility
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location, and room number. Allina also confirmed that this information should not have been disclosed because Holtzbauer had opted out of the facility directory.
Procedural History In April 2023, Holtzbauer sued Allina, seeking compensatory damages for Allina's alleged violation of the Act.7In March 2024, the parties stipulated to the following facts:
(1) Holtzbauer had opted out of Mercy's facility directory upon his admission;
(2) because he had opted out, Holtzbauer's admission to Mercy and room number were made confidential and inaccessible to the public unless Holtzbauer provided consent to Allina to share his hospital location and room number; (3) Allina did not include Holtzbauer in its facility directory; (4) when H.H. called, an Allina employee disclosed Holtzbauer's admission and room number to H.H.; (5) the Allina employee's disclosure violated Allina's Patient Privacy Rights Policy; and (6) Allina would be vicariously liable if Holtzbauer proved breach and causation under the Act.
Allina subsequently moved for summary judgment, arguing that "the name of the hospital and the room number where [Holtzbauer] was located is not a 'medical record' under the [Act]."8Holtzbauer opposed summary judgment, asserting that the information
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Allina disclosed constituted a "health record" under Minnesota Statutes section 144.291, subdivision 2(c).
The district court granted Allina summary judgment. The court relied on a nonprecedential court of appeals decision, Furlow v. Madonna Summit of Byron, No. A19-987, 2020 WL 413356 (Minn. App. Jan. 27, 2020), and determined that
"[Holtzbauer's] presence in the emergency room and his room number d[id] not explicitly go to the nature of his care or condition," and, accordingly, did not constitute a health record under the Act. The district court acknowledged Holtzbauer's argument that, in certain circumstances, patient status "may run afoul of the [Act] and serve as a de facto disclosure of a medical condition," such as "an individual's status as a patient at certain specialty clinics." But the district court found this argument unpersuasive because
"Mercy Hospital's emergency room … provides care for a large number of diseases and disorders."9
Holtzbauer appealed. In a split decision, the court of appeals reversed the district court, reasoning as follows:
Allina released "information … that relates to … the provision of health care to a patient" under the plain meaning of the definition of "health record" in Minn. Stat. § 144.291, subd. 2(c), when it revealed that Holtzbauer was a patient who was hospitalized at Mercy Hospital in a specific room …. Holtzbauer v. Allina Health Sys., 23 N.W.3d 608, 620 (Minn. App. 2025). Further, despite deciding that the definition of health record was not ambiguous, the court of appeals also
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considered the "overarching effect" of the statute and concluded its interpretation
"align[ed] both with the Health Records Act and with common sense." Id. at 619. The dissenting court of appeals judge disagreed with the majority's "broad[]"
interpretation of subdivision 2(c), asserting "the court's interpretation [wa]s not justified by the text of the statutory definition or by the context indicated by the act as a whole."
Id. at 621 (Johnson, J., dissenting). The dissent would have interpreted "health record"
"to not include the mere fact that a particular person is a patient at a particular hospital and is in a particular room." Id.
We granted Allina's petition for further review.
ANALYSIS
The question in this case is whether Allina disclosed a "health record," as defined in Minnesota Statutes section 144.291, subdivision 2(c), when it revealed to H.H. that Holtzbauer was a patient at Mercy in a particular room. Answering this question is a matter of statutory interpretation. Our review is de novo. Schneider v. Child.'s Health Care, 996 N.W.2d 197, 201 (Minn. 2023).
The Legislature defines a "health record" as follows:
"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. Minn. Stat. § 144.291, subd. 2(c). We are bound by the Legislature's definition of "health record." State v. Fugalli, 967 N.W.2d 74, 77 (Minn. 2021) (stating that "[w]hen the
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Legislature has defined a term, that meaning prevails"). The Act also prohibits a provider or person from releasing a patient's health records unless certain requirements are met:
A provider, or a person who receives health records from a provider, may not release a patient's health records to a person without:
(1) a signed and dated consent from the patient or the patient's legally authorized representative authorizing the release;
(2) specific authorization in Minnesota law; or
(3) a representation from a provider that holds a signed and dated consent from the patient authorizing the release. Minn. Stat. § 144.293, subd. 2. A person who "negligently or intentionally requests or releases a [patient's] health record in violation of sections 144.291 to 144.297" is liable to the patient for compensatory damages. Minn. Stat. § 144.298, subd. 2. We turn, then, to whether the information that Holtzbauer was a patient at Mercy in a particular room is a health record under Minnesota Statutes section 144.291, subdivision 2(c). Holtzbauer and Allina offer competing answers to that question. Holtzbauer urges that the definition of health record is broad, encompassing any information which has a connection, association, or logical relationship to the action of providing or supplying health care to a patient. According to Holtzbauer, information that a patient was admitted to a hospital and the patient's room number fall within that broad definition. Allina reads the definition more narrowly, asserting that a health record is limited to what it labels as "clinical information" about a patient. Allina posits that the Act distinguishes between a "health record" and "identifying information," which is separately defined as a "patient's name, address, date of birth, gender, parent's or
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guardian's name regardless of the age of the patient, and other nonclinical data which can be used to uniquely identify a patient." Minn. Stat. § 144.291, subd. 2(d). We address Holtzbauer's interpretation of the definition of "health record" in Part A of our opinion, and we address Allina's interpretation in Part B. We conclude that Holtzbauer's interpretation of the definition of "health record" is the only reasonable interpretation and that it includes information that Holtzbauer was a patient at Mercy and his room number there. See In re SIRS Appeal by Best Care, LLC, 26 N.W.3d 459, 468 (Minn. 2025) (stating that if the Legislature's "intent is plain from the text and context of the statute—that is, there is only one reasonable interpretation of the language—we then adopt that meaning"). Consequently, we hold that the information that Holtzbauer was a patient at Mercy and his room number is a health record under the Act.
A.
Holtzbauer maintains that the information that he was a patient at Mercy and his room number is a "health record" under the Act. For the reasons explained below, we conclude that interpretation is reasonable.
1.
Once again, a health record includes, among other things, "any information … that relates to … the provision of health care to a patient." Minn. Stat. § 144.291, subd. 2(c). We discuss each phrase below.
First, the definition of "health record" applies expansively to "any information."
The Act does not define these terms, and we rely instead upon dictionaries and our past decisions interpreting them. See Douglas v. State, 986 N.W.2d 705, 709 (Minn. 2023)
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("When statutory terms are undefined, the court may look to dictionary definitions to determine the common and ordinary meanings of these terms."); see also State v. Gorman, 546 N.W.2d 5, 8-9 (Minn. 1996) (stating past decisions from this court that
"have wrestled with a definition of the word …. may guide our interpretation of the present statute"). "Information" is generally defined broadly to mean "facts provided or learned about someone or something." Information, New Oxford American Dictionary 891 (3d ed. 2010). The Legislature's use of the phrase "any information" further bolsters this point. Minn. Stat. § 144.291, subd. 2(c) (emphasis added). In our most recent and comprehensive statement on the effect of the word "any" on statutory meaning, we explained that using the word "any" demonstrates a legislative "intent to be inclusive, not restrictive." In re Welfare of Child of B.D.D., 25 N.W.3d 707, 712 (Minn. 2025) (citation omitted) (internal quotation marks omitted) (emphasis added). We further clarified that
"[w]hen used in the affirmative, 'any' means 'every' or 'all' " and "[b]ecause 'any' is all- encompassing, we give the word broad application, 'regardless of whether we consider the result reasonable.' " Id. at 712-13 (citations omitted). We have repeatedly said that the Legislature's use of the modifier "any" indicates that the reach of the word modified by "any" is broad. See, e.g., Berrier v. Minn. State Patrol, 9 N.W.3d 368, 377 (Minn. 2024) (stating that "any potential dog owner" includes the Minnesota State Patrol); In re PERA Police & Fire Plan Line of Duty Disability Benefits of Brittain, 724 N.W.2d 512, 519 (Minn. 2006) ("By inserting the modifier 'any' before 'act of duty,' the legislature demonstrated the intent to be inclusive, not restrictive."); Hyatt v. Anoka Police Dep't,
691 N.W.2d 824, 826-27 (Minn. 2005) (concluding that the dog bite statute applies to a
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municipal owner of a police dog because the statute defines "owner" broadly as "any person harboring or keeping a dog").
While a "health record" can thus be "any information," in the rest of the term's statutory definition the Legislature detailed specific information it intended to include within that meaning. The Legislature defined "health record" using, in part, the phrase
"provision of health care to a patient." Minn. Stat. § 144.291, subd. 2(c). The definition uses the word "provision" as a noun. In this context, "provision" refers to "the action of providing or supplying something for use." New Oxford American Dictionary 1406 (3d ed. 2010). Here, "provision" refers to providing or supplying health care to a patient. The Legislature's definition also uses the phrase "relates to." Minn. Stat. § 144.291, subd. 2(c). Holtzbauer argues that this phrase also indicates the Legislature's intention that "provision of health care to a patient" be read broadly. Holtzbauer's argument is consistent with our case law. We have repeatedly interpreted the statutory phrase "relating to" as intentionally broad language. In 500, LLC
v. City of Minneapolis, we defined "relating to" to mean " 'to stand in some relation; to have bearing or concern; to pertain; refer; to bring into association with or connection with.' " 837 N.W.2d 287, 291 (Minn. 2013) (quoting Morales v. Trans World Airlines, Inc., 504 U.S. 374, 383 (1992)). In that case, a property owner whose property had been nominated for designation as a local historic landmark sought to develop the property and, accordingly, applied for a certificate of appropriateness. Id. at 289. The matter ended up before the Minneapolis City Council. Id. Under Minn. Stat. § 15.99, subd. 2(a), a
"written request relating to zoning" is approved by operation of law unless the
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municipality denies it within 60 days. 500, LLC, 837 N.W.2d at 290. The city council denied the property owner's application—but did so more than 60 days after the deadline for deciding. Id. at 289. The property owner claimed that the application had been approved automatically. Id. The city, in turn, argued that subdivision 2(a) did not apply because the application for a certificate of appropriateness was not a "written request relating to zoning" since that phrase was limited to requirements "that are explicitly authorized by an applicable zoning ordinance or statute"—and the certificate of appropriateness was not explicitly a zoning ordinance. Id. at 291. We rejected the city's narrow reading of the statute and held that an application for a certificate of appropriateness is a "written request relating to zoning." Id. at 292. In doing so, we observed that the phrase "relating to" is broad and means " 'to stand in some relation; to have bearing or concern; to pertain; refer; to bring into association with or connection with.' " Id. at 291 (quoting Morales, 504 U.S. at 383). We also noted that
"zoning" covers regulating building development and property use. Id. Putting these pieces together, we determined that a "written request relating to zoning" is a "written request that has a connection, association, or logical relationship to the regulation of building development or the uses of property." Id. We reasoned that the "broad" phrase
"relating to" "encompasses any connection, association, or logical relationship to the noun modified by the phrase—here, zoning." Id. Thus, a noun modified by the term
"relating to" should not be read narrowly or as limited to the items the noun explicitly covers. See id.
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Applying this rule in 500, LLC, we identified three reasons the certificate of appropriateness had a connection, association, or logical relationship to zoning. Id. at 292-93. First, like other zoning procedures, a certificate of appropriateness involves a property owner's use of a particular property and affects specific property rights. Id. at
292. Second, the historical preservation statute that authorized the city's historic preservation commission specifically allowed amendments to general city zoning ordinances. Id. Third, proposed alterations to historic properties must be consistent with the policies of the city's comprehensive plan implemented through the city's zoning code. Id. at 292-93.
We see no reason to depart from our approach in 500, LLC here. In this case, when we interpret Minnesota Statutes section 144.291, subdivision 2(c), we read the phrase
"relates to" broadly and apply the meaning we applied in 500, LLC. "[A]ny information"
that a person is a patient at a hospital in a particular room is a health record if the information "encompasses any connection, association, or logical relationship to the noun modified by the phrase ['relating to']"—in this case, providing or supplying health care to a patient. 500, LLC, 837 N.W.2d at 291. It is reasonable to conclude that information that a person is at a hospital in a certain room is information that encompasses some connection, association, or logical relationship to providing health care. Information that a person is in a certain room may reveal the type of health care the person is receiving or the person's diagnosis. For example, information that a person is in a room in an oncology unit may reveal that the person is being treated for or has been diagnosed with a type of cancer.
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Our decision in Phone Recovery Services, LLC v. Qwest Corp.—in which we again interpreted the phrase "relating to"—compels the same result. 919 N.W.2d 315, 320 (Minn. 2018). Phone Recovery Services required us to interpret the Minnesota False Claims Act, which "permits … a plaintiff to bring a private cause of action to collect funds due to the State" and, if successful, retain a portion of the funds recovered. Id. at
319. The tax bar provision of the False Claims Act, however, prohibits private False Claims Act lawsuits stemming from "portions of Minnesota Statutes relating to taxation."
Id. (quoting Minn. Stat. § 15C.03).
In Phone Recovery Services, the plaintiff sued Qwest to recover uncollected 911 service and other telecommunication program fees that state law required Qwest to collect on behalf of the State. Id. at 318. Qwest argued that the uncollected 911 service and other telecommunication program fees were taxes not subject to a False Claims Act lawsuit. Id. at 319. In resolving the matter, we first determined "that the plain meaning of 'portions of Minnesota Statutes relating to taxation' refers to the provisions of Minnesota Statutes that pertain, refer, or stand in some relation to the levying, imposition, assessment, or collection of taxes." Id. at 320 (citation omitted). After determining that the fees at issue were "taxes," id. at 323-25, we concluded that the statute's plain language barred the action to recover the uncollected 911 service and other telecommunication program fees. Id. at 325.
The Phone Recovery Services dissent argued that "an equally reasonable interpretation of 'relating to' would be 'about' " and that by "describing the plain meaning of 'relating to' as 'about' … the statute would retain a narrow focus." Id. at 326
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(McKeig, J., dissenting) (citations omitted). We noted that even if we were to adopt the dissent's approach and interpret "relating to" to mean "about," the result would be the same—the relevant statutory provisions would relate to taxation. Id. at 322 (majority opinion).
Here, as in Phone Recovery Services, interpreting "relating to" to mean "about"
does not produce a different result. See id. Information that a person is a patient at a hospital in a particular room is a health record if the information is about providing or supplying health care to a patient. Returning to the example above, information that a person is a patient in a room in an oncology unit may reveal that the person is being treated for or has been diagnosed with cancer. Being treated for or having been diagnosed with cancer is clearly about providing or supplying a patient health care. The same is also true for information that someone has been admitted to a room at a hospital. It is information about the potential severity or urgency of health care being provided to the patient.
Holtzbauer's interpretation that a "health record" is any information that encompasses a connection, association, or logical relationship to the action of providing or supplying health care to a patient is therefore a reasonable interpretation of the statute's plain language. Further, information that a patient was admitted to a hospital and the patient's room number falls within that broad definition because that information is connected with (and about) providing health care. A patient is not admitted to a hospital and assigned a room number if the patient is not receiving health care.
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2.
The reasonableness of Holtzbauer's interpretation finds further support in Minnesota Statutes section 144.294, subdivision 3, which provides for releasing a patient's mental health care records to family members under certain circumstances. Like the definition of "health record," the Legislature added Minnesota Statutes section 144.294, subdivision 3, as new law in the 2007 codification of the Act. Act of May 25, 2007, ch. 147, art. 10, § 5, 2007 Minn. Laws 1804, 2104. Subdivision 3 begins by stating it applies "[n]otwithstanding section 144.293"—which, as discussed above, provides the general rules governing the release or disclosure of health records. Minn. Stat. § 144.294, subd. 3. This proviso signals that Minnesota Statutes section 144.294, subdivision 3, addresses health records. Subdivision 3 then authorizes releasing a subset of information from a patient's health record—"health record information"—to family members under certain circumstances. Minn. Stat. § 144.294, subd. 3. The subset of information from a patient's health record that may be disclosed to family members includes "diagnosis, admission to or discharge from treatment, the name and dosage of the medications prescribed, side effects of the medication, consequences of failure of the patient to take the prescribed medication, and a summary of the discharge plan." Minn. Stat. § 144.294, subd. 3(b) (emphasis added). The Legislature's decision to incorporate
"admission to or discharge from treatment" into the subset of information included as part of a patient's health record tells us that information that a patient was admitted to a facility is a health record under the Act. Fugalli, 967 N.W.2d at 80 (stating that we can
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consider provisions enacted at the same time that address the same subject to determine statutory meaning).
3.
Allina argues that Holtzbauer's interpretation is unreasonable for several reasons. First, Allina asserts that Holtzbauer's reading is unreasonable because it means that health records include all information a health care provider has about a patient. We are not convinced Allina's assertion is true. But even if we assume Allina is correct, that fact does not render the interpretation unreasonable. The Legislature could rationally conclude that hospitals should not share any information about a patient without the patient's consent outside of circumstances in which the Legislature expressly allowed such disclosure.
Allina also argues that Holtzbauer's interpretation is so broad that it renders some provisions of the definition of health record meaningless. Allina points out that the statute identifies three categories of information that qualify as a "health record": (1) "any information … that relates to the past, present, or future physical or mental health or condition of a patient"; (2) "any information … that relates to … the provision of health care to a patient"; and (3) "any information … that relates to … the past, present, or future payment for the provision of health care to a patient." Minn. Stat. § 144.291, subd. 2(c). According to Allina, Holtzbauer's proposed broad reading of the second category renders the first and third categories meaningless because, under such a reading, the second category would include all information in the first and third categories, rendering those categories superfluous. We are not persuaded.
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First, there are times the Legislature enacts statutes with overlapping categories. We will not mechanically reject a reading of a statute simply because the Legislature enacted a statute with language providing more than one means to achieve its desired end. See, e.g., In re Welfare of A.J.B., 929 N.W.2d 840, 856-57 (Minn. 2019) (discussing the Legislature's belt-and-suspenders approach to the mens rea required for a certain criminal offense); see also G&I IX OIC LLC v. County of Hennepin, 979 N.W.2d 52, 64 n.3 (Minn. 2022) (Thissen, J., concurring) ("[S]ometimes the Legislature takes a belt- and-suspenders approach; we do not require purity on superfluity in all cases."). Indeed, Allina agrees that the Legislature sometimes adopts a belt-and-suspenders approach with overlapping categories. Allina, however, argues that Holtzbauer's interpretation impermissibly extends beyond a belt-and-suspenders approach because it results in one category entirely swallowing another. To avoid this, Allina argues, we should interpret the statute such that the phrase "any information … that relates to … the provision of health care to a patient" is limited to what it labels as "clinical information."
The argument is flawed for several reasons. First, the statute includes no textual hook to suggest that "clinical information" is a proper limiting principle.10Second, the superfluity canon upon which Allina relies is a narrowing canon. Yet, as discussed above, the Legislature left important contextual clues—the use of the terms "any" and "relates to"—that the definition of health record is to be construed broadly rather than narrowly.
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Finally, the categories that Allina asserts our interpretation swallows ("any information … that relates to … the present, past, or future … health or condition of a patient" and "any information … that relates to … the past, present, or future payment for the provision of health care to a patient") are themselves sufficiently broad to cover the fact of a person's admission to a hospital. That is a signal that the Legislature was not attempting to craft delineated categories. Overlap among the categories the Legislature specified fails to advance Allina's position.
Accordingly, Holtzbauer's interpretation that a "health record" as defined in Minnesota Statutes section 144.291, subdivision 2(c), includes the information that he was a patient at Mercy and his room number is reasonable.
B.
In contrast to Holtzbauer's interpretation, for the reasons discussed below, we conclude that Allina's interpretation is not reasonable. In re Est. of Ecklund, 20 N.W.3d 351, 355, 360 (Minn. 2025).
1.
Allina's argument that information that Holtzbauer was a patient at Mercy and his room number is not a health record turns on the proposition that such information falls within the distinct statutory category of nonclinical "identifying information." Allina points out that the Legislature adopted a distinct definition of "identifying information" in Minnesota Statutes section 144.291, subdivision 2(d). Subdivision 2(d) defines
"identifying information" as a "patient's name, address, date of birth, gender, parent's or guardian's name regardless of the age of the patient, and other nonclinical data which
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can be used to uniquely identify a patient." Minn. Stat. § 144.291, subd. 2(d) (emphasis added). Allina posits that the existence of these separate definitions means that a "health record" and "identifying information" are two separate, non-overlapping categories of information and, consequently, concludes that "nonclinical data which can be used to uniquely identify a patient"—like the fact a patient is admitted to a hospital and is assigned a particular room—is not a "health record."
We disagree. The phrase "identifying information" has a specific and narrow statutory role. It is used once in the Act, in Minnesota Statutes section 144.293, subdivision 8. That provision addresses the circumstances under which a provider can release information to a record locator service or a patient information service. See Minn. Stat. § 144.293, subd. 8. Record locator services and patient information services are systems that inform providers which other providers may have their patients' health records. See Minn. Stat. § 144.291, subd. 2(j) (defining record locator service as "an electronic index of patient identifying information that directs providers in a health information exchange to the location of patient health records held by providers and group purchasers"); Minn. Stat. § 144.291, subd. 2(h) (defining a patient information service as a "service providing the following query options: a record locator service as defined in paragraph (j)" or a similar electronic database maintained by a health insurance company). Those systems do not hold any actual documents. Under section 144.293, subdivision 8, a provider can release "identifying information"—a "patient's name, address, date of birth, gender, parent's or guardian's name regardless of the age of the patient, and other nonclinical data which can be used to
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uniquely identify a patient," Minn. Stat. § 144.291, subd. 2(d)—to a record locator service or patient information service for other providers to find their patients' health records. A provider, however, cannot release "identifying information" to those services if a patient opts out of such release. Minn. Stat. § 144.293, subd. 8. Subdivision 8, by allowing for release unless a patient opts out, alters the general presumption under section 144.293, subdivision 2, that patient health records cannot be released without the patient's affirmative consent.11
Contrary to Allina's argument, section 144.293, subdivision 8, confirms that
"identifying information" is a category of information included within a "health record"
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rather than a separate and distinct category of information. Section 144.293 generally addresses the circumstances under which a provider can release health records. Within this statute providing that "health records can be released or disclosed as specified," id., subd. 1, subdivision 8 functions as an exception to the general rule set forth in subdivision 2 that a health record can only be released with a patient's affirmative consent. Subdivision 8 first limits the scope of the health record information that can be released to "identifying information," then limits with whom that identifying information may be shared—an electronic database that allows providers to locate patient health records (e.g., a record locator service or patient information service). Such limitations make sense since the purpose of those systems is to allow providers to find patient health records held by a different entity; they do not hold actual clinical information. The structure of subdivision 8 within section 144.293 indicates that "identifying information"
is a subset of "health record" and not its own, separate category of information. Indeed, section 144.293, subdivision 8, would not be necessary if the definition of
"health record" were to exclude "identifying information." The statute only addresses health records, and it explicitly makes them private. Minn. Stat. § 144.293, subd. 2 (requiring a patient's consent or specific authorization of law before a patient's health record can be released). If identifying information were not a health record, there would be no need for the statute to address its release; such information could presumably be released to anyone, with or without a patient's affirmative consent. Anticipating this objection to its argument, Allina argues that subdivision 8 itself makes identifying information private. This reading "stretches the statutory text … too
28
far." Buzzell v. Walz, 974 N.W.2d 256, 264 (Minn. 2022) (rejecting an argument because it "simply stretches the statutory text … too far."); see also Fugalli, 967 N.W.2d at 78 (rejecting an argument because it "works too hard and unduly strains the ordinary meaning of the language adopted by the Legislature"). Subdivision 8 does not say that identifying information is private; indeed, no provision in the Act provides that identifying information is private.
Allina nonetheless argues subdivision 8 implicitly conveys that identifying information is private because if identifying information is not private, the subdivision does not make sense. That much is true. But that assertion does not help Allina because the most straightforward reading of section 144.293—one that does not require reading an implicit meaning into subdivision 8—is that "identifying information" is private because it is a subset of information included in the definition of health records which the statute establishes are presumptively private.
2.
We find more support for our conclusion that nonclinical identifying information is a subset of health record information in the federal HIPAA statute and the HIPAA Privacy Rule adopted under that statute. Again, the definition of "health record" that the Legislature enacted in 2007 is virtually identical to the definition of "health information"
Congress adopted when it passed HIPAA in 1996.12Accordingly, considering applicable
29
federal law sheds some useful light on the issues before us. See Ecklund, 20 N.W.3d at 360 n.8 ("We have found other portions of federal law applicable pre-ambiguity when incorporated by statute or similar in purpose and construction." (citations omitted)); cf. Henry v. Indep. Sch. Dist. #625, 988 N.W.2d 868, 880 (Minn. 2023) (stating that we will look to federal case law arising under similar federal statutes when interpreting the Minnesota Human Rights Act but specifying that any such federal case law is not binding on us).
The HIPAA Privacy Rule permits a hospital to use certain protected health information—an individual's name, location in the facility, general condition, and religious affiliation—in a facility directory. 45 C.F.R. § 164.510(a)(1). Before a hospital may include a patient's health information in a facility directory, however, it must first inform the patient of the health information it may include and to whom the hospital may disclose the information, and second, provide the patient with an opportunity to opt out of physical or mental health or condition of an individual, the provision of health care to an individual, or the past, present, or future payment for the provision of health care to an individual.
Health Insurance Portability and Accountability Act of 1996, Pub. L. No. 104-191, § 262,
110 Stat. 1936, 2022 (codified as amended at 42 U.S.C. § 1320d(4)). Less than a decade later, the Legislature provided the following definition of "health record":
"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 for a patient. Act of May 25, 2007, ch. 147, art. 10, § 2, 2007 Minn. Laws 1804, 2098 (codified at Minn. Stat. § 144.291, subd. 2(c)).
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the facility directory. Id., § 164.510(a)(2).13Notably, the HIPAA Privacy Rule is structurally similar to section 144.293, subdivision 8. Both provisions treat identifying information—and particularly hospital admission status and room number—as private. Both provisions alter the presumption for disclosure from affirmative opt-in consent to an opt-out approach. As with Minnesota Statutes section 144.293, subdivision 8, the opt-out mechanism under the HIPAA Privacy Rule to authorize the release of (among other things) a patient's name and location within a facility would be unnecessary if the information were not private to begin with—and the only information that HIPAA makes private is health information.14Thus, an individual's name and location in a facility was
31
"health information" under federal law as it existed in 2007, when the Legislature enacted the nearly identical definition of "health record."
3.
Our conclusion that "identifying information" is a subset of the information in a
"health record" also undermines Allina's related argument that the definition of health record covers only "clinical information." We begin by observing that the Act does not use the phrase "clinical information," and, specifically, the definition of health record is not limited to "clinical information." See Ecklund, 20 N.W.3d at 356 (observing that the lack of qualifying or limiting language in a statutory provision supported a broad reading of the statute). Rather, the Act uses the much broader phrase "any information."
Allina focuses our attention, however, on the words "nonclinical data" in the definition of "identifying information." That language in the definition of "identifying information," however, does not provide a textual hook to limit the definition of "health record" because, as just discussed, "identifying information" is a subset of "health record" information under the Act. If anything, the fact that the definition of identifying
(ii) With respect to which there is a reasonable basis to believe the information can be used to identify the individual.
45 C.F.R. § 160.103 (2006) (emphasis added); see also 45 C.F.R. § 160.103 (2025) (same). The Legislature adopting a definition of "health record" that is nearly identical to the contemporaneous HIPAA statutory definition of "health information" and the federal rule definition of "individually identifiable health information" provides more support for the conclusion that identifying information is included in the information that makes up a health record under the Act.
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information includes nonclinical data shows that health records include both clinical and nonclinical information about a patient.15
That conclusion, however, does not end our analysis of Allina's interpretation. Allina points to Minnesota Statutes section 144.292, subdivision 4(2), which states:
A provider shall provide to patients, in a clear and conspicuous manner, a written notice concerning practices and rights with respect to access to health records. The notice must include an explanation of … (2) the right of the patient to have access to and obtain copies of the patient's health records and other information about the patient that is maintained by the provider. Minn. Stat. § 144.292, subd. 4(2) (emphasis added). Allina argues the Legislature had no reason to include the phrase "and other information" if health records include nonclinical information.
Allina reads too much into that language. Minnesota Statutes section 144.292, subdivision 4(2), predated the 2007 codification of the Act. The language now in subdivision 4(2) existed in a predecessor statute—Minn. Stat. § 144.335, subd. 5a(2) (2006)—before being incorporated into the Act in the 2007 codification. Compare Minn. Stat. § 144.335, subd. 5a(2) (2006), with Minn. Stat. § 144.292, subd. 4(2) (2008). Before the Act's 2007 passage, the Minnesota Statutes did not define "health records." Thus, the
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belt-and-suspenders language of "health records and other information" made sense before the Legislature provided a definition of "health record." The wholesale transfer of the language "health records and other information" in the recodification tells us little or nothing about the new statutory definition of "health record."
4.
Finally, in contrast to Holtzbauer's reliance on the phrases "provision of health care," "relates to," and "any information," Allina asks us to consider the Act's use of the terms "health care" and "patient" in the definition of "health record." We consider each in turn.
Allina argues that the Legislature's use of the phrase "health care" supports its interpretation that a health record only includes clinical information. Allina asserts that
"health care" means "efforts made to maintain, restore, or promote someone's physical, mental, or emotional well-being, especially when performed by trained and licensed professionals." Allina argues that information that a person is a patient in a particular hospital in a particular room is not information about the provision of efforts to maintain, restore, or promote well-being. Even if we accept for the sake of argument that Allina's definition of health care is correct, we disagree with Allina's conclusion that the information at issue is not information about providing health care. It is reasonable to understand that information that a person is a patient at a hospital in a particular room is related to (connected to, associated with) efforts to maintain, restore, or promote that
34
patient's well-being.16We do not find Allina's argument regarding the phrase "health care" compelling.
Allina also asks us to consider the Act's use of the word "patient." The definition of "health record" includes providing health care to a patient. Minn. Stat. § 144.291, subd. 2(c). The statutory definition of "patient" reads, in relevant part, "a natural person who has received health care services from a provider for treatment or examination of a medical, psychiatric, or mental condition." Id., subd. 2(g). Incorporating that definition into the statutory definition of "health record," the statute reads, "any information that relates to the provision of health care to a natural person who has received health care services from a provider for treatment or examination of a medical, psychiatric, or mental condition." Id., subd. 2(c), (g). Allina seems to argue that the link between "health care services" and "treatment and examination of a condition" in the definition of patient limits the definition of health care to treating and examining a condition. As such, according to Allina, "the provision of health care" should be read as providing treatment and examining a condition. We are not convinced. The purpose of the word "patient" in Minnesota Statutes section 144.291, subdivision 2(c), is not to limit the meaning of providing health care; it is simply to identify who the provision covers—patients.
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* * * Based on the foregoing, we conclude that Allina's interpretation limiting the definition of health record to clinical information is not reasonable. For this reason, and because Holtzbauer's definition of health record is reasonable and covers information about Holtzbauer's admission to Mercy and his room number, we hold that Allina violated the Act when it released information about Holtzbauer's hospital admission and room number to H.H.
We acknowledge that our decision may pose challenges for hospitals, other medical providers, law enforcement, hospital chaplains, and worried families. Our decision may upset current practices in some hospitals. The policy concerns raised by Allina and its amici, the Minnesota Hospital Association; Law Enforcement Labor Services, Inc.; and Legal Defense Fund of the Peace Officers Research Association of California, about communications with caregivers and guardians of patients, access to spiritual care, and interaction with public safety personnel are very real. On the other hand, Allina's interpretation itself raises significant practical and policy concerns, including concerns about nonconsensual disclosures of private medical information and the risks such disclosures pose to patients, for example, to those who have experienced domestic violence. And we emphasize that on remand, Holtzbauer still bears the burden of proving that he suffered injury caused by Allina's disclosure and, if he did suffer injury, the amount of damages. In the end, by setting forth a general rule protecting patient privacy interests and then creating nuanced exceptions to the general rule, the Legislature engaged in sophisticated balancing between the competing policy and
36
practical concerns. The Legislature is institutionally best positioned to weigh the need for additional exceptions to the general rule or targeted exceptions to the private right of action and to enact changes to the existing framework if it determines that the current statute gets that balance wrong. "[I]t is the Legislature's prerogative to reexamine the … statute and amend it accordingly" after considering these competing policy concerns. Khalil, 956 N.W.2d at 643.
CONCLUSION
For the foregoing reasons, we affirm the decision of the court of appeals and remand to the district court for further proceedings consistent with this opinion. Affirmed.
HENNESY, J., took no part in the consideration or decision of this case. ALIGADA, Jr., J., not having been a member of the court at the time of submission, took no part in the consideration or decision of this case.