Tracker record · Texas · Judgment
Purl v. HHS: reproductive-health privacy ruling and appeal status
The Northern District of Texas (Judge Matthew J. Kacsmaryk) issued a June 18, 2025 order vacating, nationwide under the APA, the 2024 HIPAA reproductive-health privacy rule amendments at 45 C.F.R. parts 160 and 164, holding that HHS exceeded its statutory authority. The vacatur is partial: the provisions relating to 45 C.F.R. 164.520 (notice of privacy practices) concerning substance use disorder records were left in place. HHS did not appeal; the August 18, 2025 appeal deadline passed without an HHS appeal. The proposed intervenors (two city governments and a medical advocacy group) voluntarily dismissed their appeal on September 10, 2025 (per the reproduced appellate docket entry; joint filing September 14, 2025). Final as of October 13, 2026.
Status
- Legal status
- Vacated (partial); final (Vacated June 18, 2025, N.D. Tex., No. 2:24-cv-00228 (Judge Matthew J. Kacsmaryk); 45 C.F.R. parts 160 and 164 reproductive-health amendments vacated nationwide; the 164.520 substance use disorder notice provisions survive; HHS did not appeal (appeal deadline August 18, 2025 passed); proposed intervenors' appeal dismissed September 10, 2025)
- Allegation or finding
- Finding or order
- Applicability
- Nationwide: the June 18, 2025 order vacated the 2024 HIPAA reproductive-health privacy rule amendments at 45 C.F.R. parts 160 and 164 nationwide under the APA; the 164.520 substance use disorder notice provisions survive
- Enforceability
- Binding per its terms
- Procedural posture
- Final: HHS did not appeal, and the proposed intervenors voluntarily dismissed their appeal on September 10, 2025 (joint filing September 14, 2025)
- Law checked through
- October 13, 2026
- Court
- U.S. District Court for the Northern District of Texas (Judge Matthew J. Kacsmaryk)
- Docket
- No. 2:24-cv-00228
- Parties
- Purl (Carmen Purl) v. U.S. Department of Health and Human Services
- Source
- Civil Rights Litigation Clearinghouse; Data Privacy + Security Insider
Procedural events
- 2025-06-18: Order vacating the 2024 HIPAA reproductive-health privacy rule amendments nationwide under the APA (45 C.F.R. parts 160 and 164; 164.520 substance use disorder notice provisions survive)
- 2025-08-18: HHS appeal deadline passed without an HHS appeal
- 2025-09-10: Proposed intervenors' appeal dismissed (voluntary dismissal)
- 2025-09-14: Joint filing supporting the intervenors' dismissal
Related guides
- Texas Health Records, HIPAA, and Data Localization
- Privacy Litigation: Standing, Class Actions, and Arbitration