Trent v. Office of Coroner of Peoria County

PRESIDING JUSTICE HOLDRIDGE,

specially concurring:

I agree with the holding that the office of the coroner was not obligated to disclose the medical records it obtained from the attending physicians who rendered medical treatment at St. Francis Medical Center and Methodist Hospital in Peoria. However, I do not agree with the majority’s reliance upon section 7(1)(b) of the Illinois Freedom of Information Act (FOIA) (5 ILCS 140/7(1)(b) (West 2002)) to establish a privacy right of an individual extending beyond death. I am convinced that the majority’s reliance upon such a privacy interest of the deceased is misplaced as there is no common law or statutory right of privacy surviving beyond death. See National Archives & Records Administration v. Favish, 541 U.S. 157, 158 L. Ed. 2d 319, 124 S. Ct. 1570 (2004) (holding under the federal FOIA that no privacy right survives decedent; rather, postdeath privacy rests with the surviving family). Here, under privacy interest analysis, the facts would warrant disclosure, since the survivors assert no privacy interest in their own vein.

Rather, I believe that disclosure of the medical records sought from the coroner in the instant matter is prohibited under section 7(1)(a) of the FOIA, which provides:

“(1) The following shall be exempt from inspection and copying: (a) Information specifically prohibited from disclosure by federal or State law or rules and regulations adopted under federal or State law.” 5 ILCS 140/7(1)(a) (West 2002).

Here, the medical records sought from the coroner’s office were provided to it under the privacy of medical records provisions of the Code of Civil Procedure. 735 ILCS 5/8 — 802 (West 2002). I would find that the restrictions upon disclosure provided in the Code of Civil Procedure followed those medical records when they were provided to the coroner’s office pursuant to its investigation into the cause of death of C.N. Thus, like the physicians who first generated the medical records in question, the coroner, as custodian of copies of those records, must follow the same statutory limitations on any further disclosure.

Here, under the unique facts of this case, application of the Code provisions would prevent disclosure, since there would be no one available to authorize disclosure in accordance with the Code. The subject of the medical records was deceased, and the mother was excluded by application of statute as aptly discussed by the majority.

For the foregoing reasons, I concur in the judgment to affirm the circuit court.