How about a litle fire scarecrow.lol



In December of 2006, a North Carolina Court of Appeals case highlighted another strong incentive for HIPAA compliance.
Although a private litigant has no private right of action under HIPAA, in Acosta v. Byrum, 638 S.E.2d 246 (N.C.App.) (December 19, 2006) the court found that a violation of duties owed under HIPAA constituted a negligent act. This means that private litigants can bring negligence actions based on a HIPAA violation even though they cannot directly recover for the HIPAA violation itself.