Though suffering from a bipolar disorder, a form of depression, John Doe was a highly placed employee at Group Health since 1979. He took steps to avoid having his mental health treatment history become known within Group Health because he feared it would stigmatize him among his fellow employees. Among other things he used an alias when receiving inpatient services at a Group Health hospital; specifically designated his medical file at Group Health as “confidential”; went outside of Group Health for some mental health services; and declined certain Group Health reimbursements.

In 1991 an employee in Group Health's billing and claims administration department held a routine training session for at least four staff members of the mental health department. The trainer devised an exercise that called for trainees to access specific patient information from the computer and use that information to practice filling out a claim form. For the training manual, the trainer selected the actual names and consumer numbers of several Group Health patients who had obtained mental health services from other providers. The trainer made an effort to exclude Group Health employees from the examples, but she inadvertently included Doe. Under Doe's name and consumer number was a page of practice questions that the trainees were to answer regarding claim history once they had accessed Doe's computer file. One of the trainees saw that her boss was included, and the trainer had the trainees remove and discard the objectionable pages without accessing Doe's patient information. Although the trainer hadn't said that she'd selected actual mental health patients or use in the exercise, at least two trainees present did in fact conclude that John Doe received mental health services.

Doe eventually learned of the incident and filed suit against Group Health, alleging unauthorized disclosure of health care information in violation of RCW 70.02, the Uniform Health Care Information Act, which prohibits the disclosure of “health care information' without the patient's authorization. Moving for summary judgment, the defendant argued that Doe's name and consumer number, which were all the trainees saw, do not directly relate to his health care and therefore as a matter of law didn't constitute “health care information.” The defendant further contended that even if the information did so constitute, the disclosure, though unauthorized, was nonetheless permitted by the Act under the “needs to know” exception. Group Health specifically relied on the exception allowing for disclosure for certain administrative purposes, which included disclosing to a person “who requires health care information for health care education, or to provide planning, quality assurance, peer review, or administrative...services to the health care provider. But Doe responded that such disclosure is only permitted, under the Act, “to the extent the recipient needs to know the information” and while the trainees did need to know how to access records properly, the trainees didn't need to use actual names to learn how to access records. The trainees acknowledged that the exercise could have been conducted using only the consumer numbers for identification, and not names, and an expert witness testified that Group Health, without great expense, could alter its computer system so that names wouldn't be revealed during a training exercise.

Doe also sued Group Health under a common law cause of action, asserting that it had invaded his right to privacy by public disclosure of private facts. The trial court granted summary judgment for the defendant in both cases and Doe appealed.

Held: The grant of summary judgment for the defendant on the statutory claim was reversed; the grant of summary judgment on the common law claim was affirmed. On the statutory claim, the Court ruled that a material issue of fact existed for the jury as to whether it had been disclosed that Doe was the recipient of mental health treatment, which amounted to a disclosure of “health care information.” And on the “need to know exception”, the Court concluded that the training exercise was conducted to satisfy a legitimate administrative need, but that there was a genuine issue of material fact as to whether the trainees needed to know that Doe in particular had received mental health treatment. As for the common law claim, the Court held that the State of Washington does not recognize a cause of action for invasion of privacy.