Opis Management Resources, LLC v. Secretary, Florida Agency for Health Care Administration, 713 F.3d 1291

Nursing Facilities operate skilled nursing facilities in Florida and receive requests for deceased residents' medical records from spouses and attorneys-in-fact.
Facilities refused disclosure because requestors were not personal representatives under HIPAA’s Privacy Rule.
Florida statute § 400.145 requires disclosure to specified individuals (spouse, guardian, surrogate, or attorney in fact) of both current and former residents.
Florida Agency for Health Care Administration cited § 400.145 as violating HIPAA, leading to a declaratory-judgment action by the Facilities.
District court held § 400.145 is preempted by HIPAA because it conflicts with federal confidentiality aims.
Court addresses whether state law’s broad disclosure mandate obstructs HIPAA’s purposes and objectives; leaves open how to harmonize but finds preemption exists.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is Florida § 400.145 preempted by HIPAA?	Nursing Facilities: statute conflicts with HIPAA’s Privacy Rule and obstructs federal objectives.	State Agency: § 400.145 supplements HIPAA by defining who may act as a personal representative.	§ 400.145 is preempted by HIPAA.

Maryland v. Louisiana, 451 U.S. 725 (1981) (Supremacy of federal law when conflicts arise)
PLIVA, Inc. v. Mensing, 131 S. Ct. 2567 (2011) (conflict preemption principles under express preemption)
Arizona v. United States, 132 S. Ct. 2492 (2012) (express preemption and congressional intent)
Chamber of Commerce of U.S. v. Whiting, 131 S. Ct. 1968 (2011) (plain-text preemption analysis)
Altria Grp., Inc. v. Good, 555 U.S. 70 (2008) (read justiciability of preemption readings; disfavors pre-emption when possible)
S.C. Med. Ass’n v. Thompson, 327 F.3d 346 (4th Cir. 2003) (privacy protections under HIPAA)
Citizens for Responsible Gov’t v. Leavitt, 428 F.3d 167 (3d Cir. 2005) (HIPAA Privacy Rule overview and interpretation)