is fair to conclude that appellee harbored a subjective expectation of privacy in his medical records. . III. Society’s Expectation The question, then, becomes whether society is willing to recognize appellee’s expectation as a reasonable one. The Fourth Amendment’s protections do not rest on views of the citizens of an individual state, but rather, on a broader societal perspective. Greenwood, 486 U.S. at 43, 108 S.Ct. at 1630. Reviewing the decisions of those states which have addressed this issue, however, fails to yield a societal consensus on the protection accorded to medical records. Outside of the criminal context, courts have held that an individual possesses a substantial privacy interest in his or her medical records. See McDonnell v. U.S., 4 F.3d 1227, 1253 (3rd Cir.1993) (<HOLDING>) and cases cited therein; Tarrant County Hosp.
holding that individual has privacy interest in medical information including diagnosis holding that bargaining unit employees have some nontrivial privacy interest in nondisclosure of their home addresses under the freedom of information act and concluding that that interest substantially outweighed the virtually nonexistent public interest in disclosure under foia and the privacy act not the nlra holding that personnel records or conduct investigative records regarding police officers are exempt from disclosure under virginias freedom of information act which exempts personnel records from disclosure holding that constitutional right of privacy does not apply to medical records recognizing privacy interest in medical records requested under freedom of information act