Breach of confidentiality is a medical malpractice claim

A young woman named Schwartz was counseling with Margo Gilbert while Schwartz worked as a phlebotomist at Beaumont Hospital.  She learned that Gilbert had been hospitalized at Beaumont, and informed Gilbert during a counseling session that she had accessed Gilbert's hospital records.  Gilbert complained to the hospital, and Schwartz was fired. 

Schwartz then filed suit against the psychologist, complaining of Gilbert's breach of physician-patient confidentiality.  Schwartz did not comply with the rules governing medical malpractice, however.  The Court held that an action against a psychologist under MCL 333.18237 must comply with the tort "reform" rules regarding medical malpractice, including the shorter statute of limitations and the Notice of Intent and Affidavit of Merit requirements.