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Posted November 5th, 2026 in Top Stories, Legal Insights with Tags

MN Supreme Court: Patient Identity and Room Number Are Protected “Health Records” Under the MHRA

Yesterday, the Minnesota Supreme Court decided Holtzbauer v. Allina Health System, a case that may affect organizations subject to the Minnesota Health Records Act (MHRA). The Court held that information identifying someone as a patient at a particular hospital, including the patient’s room number, is a protected “health record” under the MHRA, even though it is not clinical information. The Court explained that the MHRA broadly protects information related to the provision of health care, not just diagnoses or treatment.

What this means for your organization: Be cautious about disclosing information that identifies an individual as a patient or reveals where they received care, even without clinical details. That information may be a “health record” protected under the MHRA.

This is significant because, unlike HIPAA, the MHRA allows individuals to sue for damages for improper disclosures. The Court acknowledged that its ruling may affect common practices, such as sharing patient information with family members, law enforcement, and clergy. It concluded, however, that creating additional exceptions is up to the Minnesota Legislature.

If you have questions about how this decision affects your policies, please contact a member of our Health Care team.

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