Horton v. Willis-Knighton Medical Center
Summary
Horton brought a putative class action alleging that Willis-Knighton’s use of Meta-Pixel disclosed patients’ private health information to Facebook for targeted advertising. On appeal from a remand order, the Fifth Circuit held that Willis-Knighton could not invoke federal officer removal because it failed to satisfy the federal-direction requirement; this was a jurisdictional ruling, not a determination of liability.
Litigation Status
Procedural Posture
Willis-Knighton appealed the district court’s order granting Horton’s motion to remand following removal from Louisiana state court under the federal officer removal statute.
Reported Holding
The Fifth Circuit held that Willis-Knighton failed to satisfy the requirement of acting pursuant to a federal officer’s direction and therefore could not invoke federal officer removal. The excerpt does not include the final disposition language.
What the Court Decided
Willis-Knighton’s creation of an online patient portal did not satisfy the federal-direction requirement for federal officer removal.
What the Court Did Not Decide
The court expressly declined to consider the other federal officer removal requirements. The excerpt contains no decision on the merits of the privacy or unjust enrichment claims.
Significance
Generally viewed as plaintiff-favorable. Characterizations of significance describe how the matter has generally been discussed in tracked public sources; individual holdings are often narrow, procedural, or fact-specific, and this page does not state or imply broader holdings than the sources support.
What This Page Does and Does Not Say
This page reports what our tracked public sources say about this matter — including, where identified, the procedural posture (for example, a ruling on a motion to dismiss is not a final merits decision). It does not report legal conclusions beyond those sources, does not predict outcomes, and does not constitute legal advice.
Technologies at Issue
- Online patient portal
- Meta-Pixel
Third parties named or identified in tracked sources: Facebook.
Statutes Invoked
- Louisiana Electronic Surveillance Act, La. Stat. Ann. § 15:1303; 28 U.S.C. § 1442(a)(1); 28 U.S.C. § 1447(d); HITECH Act, Pub. L. No. 111–5, 123 Stat. 226
Claims Asserted
- Louisiana Electronic Surveillance Act
- Unjust enrichment
What This Matter May Mean for Website Operators
For operators using similar technologies, the recurring factual questions in matters like this one are whether advertising pixels transmit page URLs or hashed form data before a consent choice. Our scanner tests these behaviors empirically.
Detection of a similar technology on a website is an informational risk indicator, not a legal conclusion, and nothing in this section is legal advice.
Related Intelligence
Sources
About This Page
Publisher: Inspection-Ready Institute, Inc. (DBA Crandall Consulting), an independent website compliance and risk consultancy. We are not a law firm and nothing on this page is legal advice.
How this content is produced: Facts are extracted from publicly available sources — court and government materials, recognized legal press, professional analysis, and industry reports — by our litigation intelligence engine, stored with full source provenance, and rendered from the database. Risk guidelines are computed by a deterministic formula, never by an AI model directly. See the full methodology.
Limitations: Counts labeled "Tracked" reflect matters identified in our source set and are not official court statistics. We report what courts decided and did not decide; we do not predict outcomes.
Corrections: If you believe anything on this page is inaccurate, contact us via the contact page and we will review the underlying sources promptly.
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