Doe v. Chao was a -1... 2004 decision of the For other uses, see United States (disambiguation) and US (disambiguation). The United States of America, also referred to as the United States, U.S.A., U.S., US, America¹, or the States, is a federal republic of fifty states, mostly in central North America. The U.S. has three land... United States The supreme court in some countries, provinces, and states, is the highest court in that jurisdiction and functions as a court of last resort whose rulings cannot be appealed. In the United States, for example, there is a federal Supreme Court as well as supreme courts within most of the... Supreme Court that interpreted the statutory damages provision of the Privacy Act of 1974.

Prior to the case, lower federal courts had split over whether plaintiffs whose rights were violated were automatically entitled to the statutory minimum damages award of $1000, or whether those plaintiffs had to prove that they had suffered at least some actual damage from the privacy breach (which would then be raised to $1000 if their actual damages were less than that).

The Court's 6-3 decision determined that the latter interpretation was correct; as a result, it will be more difficult for a plaintiff to prevail as he or she must now prove both a violation and some damages before being entitled to recovery.

This result is generally applauded by proponents of greater freedoms for the press, as a contrary result may have made government agencies more reluctant to release information out of fear of lawsuits.

Background of the Case

The plaintiff in the case, coal miner Buck Doe (a A pseudonym or allonym is a name (sometimes legally adopted, sometimes purely fictitious) used by an individual as an alternative to their birth name. Contents // 1 Pseudonyms in print 2 Noms de guerre: Pseudonyms in war and guerilla 3 Pseudonyms in entertainment 4 Other pseudonyms 5 See also 6 External... pseudonym), filed for benefits under the federal Pneumoconiosis is a lung condition caused by the inhalation of dust, characterized by formation of nodular fibrotic changes in lungs. Many substances can cause pneumoconiosis including asbestos, silica, talc and metals. Depending on the type of dust, variants of the disease are considered. For example there are silicosis, also known... Black Lung Benefits Act, 30 U.S.C. §901 et seq. The Department of Labor, which ran the benefits program, required applicants to provide a This article needs cleanup. Please edit this article to conform to a higher standard of article quality. In many countries, a Social Security number is a number issued to citizens and other inhabitants for dealing with the Social Security administration and other purposes. Contents // 1 United States of America 1... Social Security number as a part of the application. The government's practice was to use the number for identification purposes, and as a result, claimants such as Doe had their Social Security numbers displayed on various legal documents and published in case reporters and online legal research databases.

Doe, along with six other black lung claimaints, sued the Department of Labor for violating their rights under the Privacy Act. The government conceded that it had violated the statute. At trial, Doe testified that he suffered "distress" from the release of his private information. The district court awarded Doe $1000, which was the statutory minimum amount of damages that could be awarded under the statute.

The Fourth Circuit reversed. It interpreted the statute to require a plaintiff to show some actual damages before the statutory minimum damages could be awarded. Further, it found that plaintiff's testimony about his "distress" was not legally sufficient to show that he had been damaged by the disclosure.

This decision conflicted with decisions of the First, Fifth, Ninth, Eleventh, and District of Columbia circuits, and the Supreme Court granted In English Law certiorari (Latin, to inform) is a public law relief (i.e. something for which you ask the court in order to deal with an action of the Government, council or other (quasi)_governmental organisation.) See judicial review and writ. An order of certiorari is given by a... certiorari to resolve the dispute.

The Statutory Language

The statutory language at issue provided that if a government agency violated the act "in a manner which was intentional or willful, the United States shall be liable to the individual in an amount equal to the sum of actual damages sustained by the individual as a result of the refusal or failure, but in no case shall a person entitled to recovery receive less than the sum of $1,000."

The Court's Decision

The Court, in an opinion written by Justice David Hackett Souter (born September 17, 1939) has been a US Supreme Court Associate Justice since 1990. He filled the seat vacated by William J. Brennan. Souter was born in Melrose, Massachusetts. He was the only child of Joseph A. Souter and Helen Hackett Souter. His father was a banker... David Souter, agreed with the Fourth Circuit's interpretation as a matter of "straightforward textual analysis."

The Court supported its interpretation with an analysis of the history of the statute, which showed that Congress specifically removed language from the bill that explicitly would have awarded $1000 without proof of any damages. (Justice Justice Antonin Scalia Antonin Scalia (born March 11, 1936) has been a US Supreme Court Associate Justice since 1986. He is widely considered the leading conservative voice on the Court. Antonin Scalia was born in Trenton, New Jersey. His mother, Catherine, was born in the United States; his father, S... Antonin Scalia, an opponent of using legislative history in interpreting statutes, did not join this paragraph of the opinion).

Justice Ruth Joan Bader Ginsburg (born March 15, 1933) is a United States jurist. Since 1993, she has served as an Associate Justice on the U.S. Supreme Court. Contents // 1 Early Life 2 Womens Rights Advocate 3 Judicial Career 4 External links Early Life Ginsburg was born Joan Ruth... Ruth Bader Ginsburg wrote a dissenting opinion, arguing that a "sensible" reading of the statutory language supported Doe's position. She also noted that reading the statute to require some proof of actual damages would have little practical effect. She noted that it would be very easy for a plaintiff to prove actual damages in a similar case merely by purchasing a A credit report summarizes historical financial information collected to determine an individuals or an entitys credit worthiness, that is, the means and willingness to repay an indebtedness. Financial institutions utilize credit reports to gauge credit reputation, and thus determine whether to extend credit, and on what terms. With... credit report following the publication of his Social Security number. This small amount of damages would then be raised to $1000 by operation of the statute.

Justice Stephen Gerald Breyer (born August 15, 1938) has been a US Supreme Court Associate Justice since 1994. Breyer was born in San Francisco, California. He married Joanna Hare in 1967, and has three children Chloe, Nell, and Michael. He graduated from Lowell High School and received an A.B. from... Stephen Breyer also dissented, noting that the government's stated fear of large damage awards under a more permissive reading of the statute would likely not materialize, as courts had interpreted the statute to only permit damages where the government released private information in bad faith (as opposed to accidentally).

References

• Information for Doe v. Chao on the OYEZ Project (http://www.oyez.org/oyez/resource/case/1649/)
• Full text of the decision courtesy of Findlaw.com (http://laws.findlaw.com/us/000/02-1377.html)