Brownbridge (1986), 183 Cal.App.3d 836, 228 Cal.Rptr. 545, 549. In Cutter, the California court explained: [T]he right to control circulation of personal information is fundamental. This right reaches beyond the interests protected by the common law right of privacy, and may be protected from infringement by either the state or by any individual. The “zones of privacy” created by article 1, section 1, extend to the details of one’s medical history. And, an “individual’s right to privacy encompasses not only the state of his mind, but also his viscera, detailed complaints of physical ills, and their emotional overtones.” Cutter, 228 Cal.Rptr. at 549 (citations omitted). See also Dr. K v. State Bd. of Physician Quality Assur. (Md. Ct. Spec. App. 1993), 98 Md.App. 103, 632 A.2d 453, 457 (<HOLDING>). Although medical records have not been
holding that every citizen has a constitutional right of privacy in his or her medical records recognizing a constitutional right of privacy in mental health records holding that constitutional right of privacy does not apply to medical records holding prisoners had no clearly established right to privacy in medical records in 1995 recognizing privacy interest in medical records requested under freedom of information act