The District Court of Appeal of Florida, Fourth District, held that neither a hearing nor a court order was required for a prosecutor to access patients' medical records from an HIV and AIDS clinic in a criminal Medicaid fraud investigation. Florida statutes contain no such requirement, and the court stated that a criminal investigation establishes a compelling need to invade the patients' right to privacy. The court also found that, under Florida statute, the medical records were sufficiently protected from further disclosure unless the patient consented.