Doe v. Delie

Dismissal of 1983 case, based on prison officials' failure to keep plaintiff inmate's HIV-positive status confidential, affirmed because 14th Amendment's protection of an inmate's right to medical privacy was not clearly established at time of defendants' conduct, and defendants were, therefore, entitled to qualified immunity.

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Argued September 11, 2000

John Doe, a former inmate of the Pennsylvania Department of Corrections, is HIV-positive. He was informed by the medical staff at the State Correctional Institution at Pittsburgh (SCIP) that his medical condition would be kept confidential. However, because of certain practices permitted by prison officials, Doe’s condition was not kept confidential. Doe sued under 42 U.S.C.S 1983, claiming that prison practices violated his right to medical privacy under the Fourteenth Amendment and under the Pennsylvania Confidentiality of HIV-Related Information Act, 35 P.S. S 7601 et seq. The District Court granted defendants’ motions to dismiss the S 1983 claims on the basis of qualified immunity, declined jurisdiction over the state claims, and dismissed the case.

Although we ultimately agree that defendants ar e entitled to qualified immunity, we do not agree with the District Court’s reasoning. We hold that the Fourteenth Amendment protects an inmate’s right to medical privacy, subject to legitimate penological interests. However , because this right was not clearly established at the time of defendants’ conduct, we will affirm the dismissal of Doe’s complaint.

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