Nature of the Case
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Facts
P held two jobs. By day he worked for a federal agency and at night he worked as a janitor for a company that contracted to clean the Department of State. D had been diagnosed with HIV in August of 1985. D had not told anyone at his janitorial job that he was HIV positive. One of his co-workers in the evenings at the State Department was Tijuana Goldring, who also held a day position at the Washington Hospital Center as a temporary receptionist. On April 13, 1996, P went to WHC's emergency room suffering from severe headaches, nausea, and high fever. He was discharged on April 16, 1996, but was unable to return to work for two weeks because of these health problems. WHC is owned by D. On April 23, 1996, P returned to WHC for a follow-up. P stopped by the receptionist's desk to pay Goldring a 'courtesy call.' Goldring asked him for the correct spelling of his uncommon last name because she wanted to send him a get-well card. P never received a card from Goldring but did receive a card from fellow co-workers at the State Department with $50 enclosed. Goldring told another co-worker at the State Department, that P had HIV. P learned that his co-workers at State knew of his AIDS diagnosis. On April 25, 1996, when collecting a paycheck two were laughing as P approached, and said to him, 'Hey motherfucker, I hear you're dying of AIDS.' P saw another worker who told him that Tijuana was 'going around telling everybody you got AIDS.' P's time at work after April 25, was 'like a living hell,' as he was teased, ridiculed, pitied, and scorned. Co-workers who had previously eaten with him now shunned him, and he was the object of snide remarks, stares, and unwanted attention. This included crass comments such as Doe has 'that faggot thing,' and '[don't] eat [Doe's] food.' Goldring denied telling anybody anything. On May 21, 1996, Doe called WHC and spoke with the vice president of personnel and human resources to ask if the hospital had a policy on employees who disseminate confidential medical information. D was referred to the hospital's 'risk management' department. P sued D and Goldring on May 20, 1997, alleging invasion of privacy and breach of confidential relationship. The jury found D liable for breach of confidential relationship and awarded damages of $250,000. The jury found against P on the invasion of privacy claim because Goldring's disclosure was not within the scope of Goldring's employment with WHC. The jury was instructed on the statute of limitations and accrual of actions. the jury explicitly found that the lawsuit was filed within the one-year limitations period. D filed a motion for judgment as a matter of law, alleging that P's breach of confidentiality claim was time-barred by the applicable one-year statute of limitations. The court ruled the limitations period commenced on April 25, 1996. It held that by that time there were more than ample circumstances to put a reasonable person in P's position' on notice that Goldring's guilt was substantial. It granted D judgment. P appealed.
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