They probably have no legal obligation to her. But, as I mentioned above, properly trained health care professionals will simply refuse to comment on issues like this. Otherwise, you could do an end-run around the privacy rules through a process of elimination (if ten hospitals tell you someone was not a patient but the 11th refuses to comment, you can deduce that the person might have been a patient).
Do you really think that hospital personnel will say nothing, or do you think that the hospital personnel will cooperate with the reporter and at least check hospital records to see if a John Mirse was ever a patient at that Hawaii hospital?
If they have received proper training by legal counsel, they will tell you that the hospital does not reveal anything about their patient list, period.
I say that the Hawaii hospital would have no legal restraints to at least tell the reporter whether or not a John Mirse was ever a patient at the hospital, the main reason being that I was dead.
Your legal privacy rights do not go away when you die. They simply come under the control of your estate
With the passage of HIPAA, hospitals have gotten very careful about what they reveal. For example, when a co-worker of mine called the hospital where my wife gave birth to our son to confirm they were still there so he could send flowers, the hospital would not even confirm that fact.
Hawaii law requires hospitals to maintain records for 25 years (i.e., back to 1983).
I recently had occasion to try to uncover some information about events in the childhood of a 55-year old man. These events took place AT MY HOSPITAL, and he was MY PATIENT.
The fact is, records are not stored for 45 years by any hospitals, anywhere, and it's very, VERY unlikely that list information (admissions, discharges, deliveries) from 1961 would have been digitized before being destroyed in 1986, since scanning and database technology was just beginning.
I'm sure the reason these hospitals have no records of Stanley Ann Dunham in 1961 is because they have no records of any kind from that era - and haven't had any since they were destroyed in 1986, as allowed by law.