E.J., a minor by his mother and father Victor and Lynell Jeffrey v. Paul Okolocha, M.D., Okolocha Medical Corp., and Okolocha Medical, Pain and Weight, 972 N.E.2d 941

Adoptive parents sought prenatal records of the birth mother and baby but did not receive prenatal records from the birth mother’s doctor.
Doctor refused to release records due to an unpaid bill and an allegedly non-compliant authorization form.
Adoption finalized before the birth records were obtained; later, neurological defects in the child were discovered.
Jeffreys filed negligence claims against Dr. Okolocha for failing to timely provide the prenatal records.
Trial court granted summary judgment for Dr. Okolocha; on appeal, the issue is whether a duty to release records existed under HIPAA and Indiana law.
Court affirmed summary judgment, holding no duty without a valid authorization compliant with HIPAA and state law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a duty to release prenatal records exists as a matter of law	Jeffreys argue Dr. O owed a duty upon presentation of a signed authorization	Okolocha contends no duty due to invalid authorization	No duty; summary judgment for Okolocha affirmed
Validity of the HIPAA authorization and Indiana release requirements	Authorization complied with HIPAA/Indiana law	Authorization failed core HIPAA/Indiana requirements	Authorization invalid; no legal release under both HIPAA and Indiana law
Preemption analysis between HIPAA and Indiana law	HIPAA preempts conflicting state law; compliance suffices	No preemption conflict; state law procedures apply	Preemption analysis unnecessary; HIPAA and Indiana law can be satisfied concurrently; no conflict found

In re C.B., 865 N.E.2d 1068 (Ind. Ct. App. 2007) (HIPAA privacy protections recognized)
In re A.H., 832 N.E.2d 563 (Ind. Ct. App. 2005) (HIPAA and privacy considerations cited)
State v. Eichhorst, 879 N.E.2d 1144 (Ind. Ct. App. 2008) (HIPAA authorization requirements noted)
A.S. v. LaPorte Reg’l Health Sys., Inc., 921 N.E.2d 853 (Ind. Ct. App. 2010) (negligence duty framework; summary judgment on duty noted)
Breining v. Harkness, 872 N.E.2d 155 (Ind. Ct. App. 2007) (summary judgment standards; standard of review)