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The Third Circuit Joins the Second, Fourth, Fifth, Seventh, Eighth, Ninth, and Tenth Circuits in HIPAA Ruling

The Third Circuit Joins the Second, Fourth, Fifth, Seventh, Eighth, Ninth, and Tenth Circuits in HIPAA Ruling
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In a three-page non-precedential opinion, the Third Circuit in Byrne v. Berks County Jail, et al., 24-1193, 2024 WL 2794446, at *1 (3d Cir. May 31, 2024) followed the majority of fellow federal circuit courts in holding that HIPAA does not provide a private right of action. Under 42 U.S.C. § 1320d-5(a)(1)), HIPAA delegates enforcement authority to the Secretary of the Department of Health and Human Services.