## Facts

- The University of Iowa Hospitals and Clinics maintained an experimental bone marrow transplant registry containing individuals’ identities and tissue-typing information produced by hospital testing.
- William Head, a leukemia patient receiving chemotherapy out of state, was told the registry included a woman (“Mrs. X”) who might be a compatible donor, with compatibility described as rare.
- Mrs. X underwent tissue typing at the hospital to evaluate her suitability as a platelet donor for an ill family member; her information was later placed into the bone marrow registry without her knowledge or consent.
- When contacted after Head’s inquiry, Mrs. X stated she was not interested in donating bone marrow and would consider doing so only for a family member.
- Head asked the hospital either to contact Mrs. X again on his behalf or to disclose her identity to him or his attorney so that he could request reconsideration by letter.
- The hospital refused, asserting the identity and tissue-typing entry were confidential under Iowa’s public records law.
- Head filed an equitable action seeking a mandatory injunction compelling disclosure; the district court ordered a court-supervised disclosure mechanism.
- The Iowa Supreme Court granted interlocutory review, stayed the disclosure order, and considered whether the record was exempt from public access.

## Issues

1. Whether a hospital registry entry identifying a potential donor and containing tissue-typing information is a confidential “hospital record” of a patient’s “condition, diagnosis, care, or treatment” exempt from disclosure under Iowa Code § 68A.7(2).
2. Whether a court may order limited or selective disclosure under the public records statute as an equitable compromise when full public disclosure would be inappropriate.

## Decision

- The Supreme Court of Iowa reversed the district court and vacated the disclosure order.
- The court held the registry entry was exempt as a confidential hospital record under Iowa Code § 68A.7(2).
- The court rejected the district court’s attempt to permit controlled, selective disclosure through a court-supervised letter process, concluding the statute does not authorize selective access.

## Legal Principles

- Iowa’s public records statute provides general public access to nonexempt records; a request is not treated as a special-access mechanism tailored to a particular requester.
- Under Iowa Code § 68A.7(2), “hospital records” include medical information generated by hospital procedures and tied to an identified individual, even if the procedure was performed to evaluate the individual as a donor rather than to treat the individual’s own illness.
- Tissue typing and related biological data maintained with an individual’s identity constitute hospital records concerning that person’s “condition, diagnosis, care, or treatment” for confidentiality purposes.
- Courts may not circumvent statutory confidentiality by ordering limited disclosure to selected persons; if a record is nonconfidential under the statute, it is open to the public generally, and if confidential, it is not subject to compelled disclosure under chapter 68A.

## Conclusion

The Iowa Supreme Court held that a state hospital’s donor tissue-typing registry entry, including the donor’s identity, is a confidential hospital record exempt from disclosure under Iowa’s public records law, and that courts cannot order selective disclosure as an equitable workaround to statutory confidentiality.


Head v. Colloton, 331 N.W.2d 870 (Iowa 1983)