out of context that makes sense...but in the context of a case report how do you implement that? The patients have privacy rights and the authors/doctors have a responsibliity to protect them. That doesn't justify this but it does force a conversation about what 'every single data point' means. Does it mean the patient's real name and social security number? their complete medical chart?
Case reports are descriptive not determinative and should be treated as such by other scholars. They are 'I saw this' not 'this is generalizably true'. They can (and often are) replicated or countered but they are not per se research as you are thinking about it. Whether it is fictitious or not, other scholars should be cautious in citing them as proof/evidence in papers that fit into the 'research' mold.
From a legal perspective, journal article authors can implement this by following the official HHS guidance for de-identification. This applies to any use of protected health information (PHI), not just case reports.
https://www.hhs.gov/hipaa/for-professionals/special-topics/d...
The IRB for a particular organization can impose additional restrictions.