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Enforcement ActionLow RiskMultistate

AGs Challenge DOJ Subpoena for Transgender Youth Medical Records

U.S. Department of JusticeOctober 30, 2025California Attorney General

Summary

California Attorney General Rob Bonta joined 15 attorneys general in filing an amicus brief to limit a U.S. DOJ subpoena seeking medical records of transgender youth from Children's Hospital of Philadelphia, arguing it violates patient privacy and could intimidate providers of gender-affirming care.

Remedy

The amicus brief urges the court to quash or limit the U.S. DOJ subpoena to protect patient privacy and prevent intimidation of healthcare providers.

Contract Impact

In-house legal teams should review all agreements involving the handling of sensitive health data, particularly vendor and data processing agreements with healthcare providers, research institutions, and cloud service providers. Focus on clauses governing data sharing, patient consent (especially for minors), government data requests/subpoenas, and compliance with HIPAA and state medical privacy laws. Contracts may need amendments to explicitly restrict disclosure of sensitive health information related to gender-affirming care without robust judicial oversight, require advance notification to the data subject/covered entity before complying with broad subpoenas, and incorporate stricter data minimization and security protocols for highly sensitive health records. Employee agreements with healthcare providers should also be reviewed for confidentiality provisions regarding patient care decisions.

Contract Search Terms

medical records disclosure clausepatient consent for data sharingHIPAA business associate agreementsensitive health information protocolsubpoena response proceduredata minimization provisionminor patient privacy addendumgovernment data request policybreach notification for health datadata retention and destruction schedule

Laws Cited

Food, Drug, and Cosmetic Act (FDCA)

Violation Types

Entity Details

Entity

U.S. Department of Justice

Also known as: Department of Justice

Industry

Healthcare

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"U.S. Department of Justice’s (U.S. DOJ) subpoena"
Violation Types
"subpoenas targeting the medical records of transgender youth"
Violation Types
"sensitive medical records and personally identifying information about adolescent patients and their families"
Laws Cited
"Food, Drug, and Cosmetic Act (FDCA)"
Is Multistate
"joining a coalition of 15 attorneys general"
Co Enforcers
"Joining Attorney General Bonta in submitting the amicus brief are the attorneys general of Connecticut, Colorado, Delaware, the District of Columbia, Illinois, Massachusetts, Maryland, Minnesota, Nevada, New Jersey, New York, Oregon, Vermont, and Washington."

Related Enforcement Actions

CA

U.S. Department of Justice

California Attorney General Rob Bonta joined a multistate coalition in filing an amicus brief opposing the U.S. Department of Justice's subpoena for patient records from University of Pittsburgh Medical Center related to gender-affirming care. The brief argues that the subpoena violates patient privacy, infringes on states' rights to regulate medicine, and exceeds DOJ's statutory authority.

CA

U.S. Department of Justice

California Attorney General Rob Bonta joined 20 attorneys general in filing an amicus brief to quash a U.S. DOJ administrative subpoena seeking sensitive medical records and personally identifying information of adolescent patients receiving gender-affirming care at Children's Hospital Colorado. The brief argues the subpoena violates states' rights to regulate medicine under the Tenth Amendment and misinterprets the Food, Drug, and Cosmetic Act, which would harm off-label drug use across all medical fields.

CA

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