District Court Judge Dismisses Texas HIPAA Privacy Rule Lawsuit: We Are Thankful for HIPAA

On November 24, 2025, the U.S. District Court for the Northern District of Texas dismissed a 2024 lawsuit filed by the Texas Attorney General (AG) against the U.S. Department of Health and Human Services (HHS) and some of the agency’s senior staff, alleging that HHS exceeded its statutory authority when issuing the HIPAA Privacy Rule to Support Reproductive Health Care Privacy Final Rule in April 2024 (89 Fed. Reg. 32976). As previously explained in our article describing the initial 2024 lawsuit, the interesting twist in this lawsuit was that one of the Texas AG’s proposed remedies was to challenge the validity of the entire 2000 HIPAA Privacy Rule (65 Fed. Reg. 82462).

Judge James Wesley Hendrix dismissed the Texas AG’s suit without prejudice based on a joint stipulation between both the state of Texas and HHS. While this challenge to HIPAA’s validity has ended, it remains to be seen whether states continue to take advantage of the current administration’s shift towards a more relaxed regulatory environment, especially in the wake of the Supreme Court of the United States’ decision in Loper Bright.

If you were hoping that this lawsuit marked the end of HIPAA as we know it, we’re sorry to disappoint – we don’t see that happening any time soon! For all those comfortable with the status quo, you have one more thing to be thankful for this week. Our team will continue to track any litigation and any other changes to both the HIPAA Privacy and Security Rules.

For more information about HIPAA compliance generally, please contact your Quarles attorney or:

• Simone Colgan Dunlap: (602) 229-5510 / simone.colgandunlap@quarles.com
• Sarah Erdmann: (414) 277-5512 / sarah.erdmann@quarles.com
• Kaitlyn Slack: (202) 780-2642 / kaitlyn.slack@quarles.com