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Quinn v. Stone

Facts

Civilian employees of the army had permits to hunt deer on army property. Security personnel annotated a hunting roster when the hunters checked in. Investigations ensued based upon information contained in the roster and a time sheet of one of the employees to determine whether the employees had killed more deer than allowed. The employees brought actions alleging violations of the Privacy Act that caused damages as the result of the disclosed information, and they sought an order directing the army to purge its files relating to the investigations.

Civilian employees of the army had permits to hunt deer on army property. Security personnel annotated a hunting roster when the hunters checked in. Investigations ensued based upon information contained in the roster and a time sheet of one of the employees to determine whether the employees had killed more deer than allowed. The employees brought actions alleging violations of the Privacy Act that caused damages as the result of the disclosed information, and they sought an order directing the army to purge its files relating to the investigations.

Issue

Whether the information disclosed by the Army regarding the civilian employees violated the Privacy Act, and whether the district court erred in granting summary judgment in favor of the Army.

Whether the information disclosed by the Army regarding the civilian employees violated the Privacy Act, and whether the district court erred in granting summary judgment in favor of the Army.

Rule

In order to maintain a suit for damages under the Privacy Act, a plaintiff must advance evidence to support a jury's finding of four necessary elements: (1) the information is covered by the Act as a 'record' contained in a 'system of records'; (2) the agency 'disclosed' the information; (3) the disclosure had an 'adverse effect' on the plaintiff; and (4) the disclosure was 'willful or intentional.'

In order to maintain a suit for damages under the Privacy Act, a plaintiff must advance evidence to support a jury's finding of four necessary elements: (1) the information is covered by the Act as a 'record' contained in a 'system of records'; (2) the agency 'disclosed' the information; (3) the disclosure had an 'adverse effect' on the plaintiff; and (4) the disclosure was 'willful or intentional.'

Analysis

The court found that the information on the roster and time card was covered by the Privacy Act, and that the information was disclosed within the terms of the Act. The court determined that there was sufficient evidence for a jury to find that the investigation and subsequent injuries were caused in significant part by the disclosure. The court also noted that the employees failed to exhaust administrative remedies set forth in the Act, which justified the district court's refusal to purge the files.

The court found that the information on the roster and time card was covered by the Privacy Act, and that the information was disclosed within the terms of the Act. The court determined that there was sufficient evidence for a jury to find that the investigation and subsequent injuries were caused in significant part by the disclosure. The court also noted that the employees failed to exhaust administrative remedies set forth in the Act, which justified the district court's refusal to purge the files.

Conclusion

The court reversed the district court's grant of summary judgment for the army as it pertained to the disclosure of civilian employees' information under the Privacy Act and affirmed that part of the district court's decision refusing to purge files related to subsequent investigations.

The court reversed the district court's grant of summary judgment for the army as it pertained to the disclosure of civilian employees' information under the Privacy Act and affirmed that part of the district court's decision refusing to purge files related to subsequent investigations.

Who won?

The appellants, Quinn and Merritt, prevailed in part as the court reversed the summary judgment regarding the disclosure of their information under the Privacy Act.

The appellants, Quinn and Merritt, prevailed in part as the court reversed the summary judgment regarding the disclosure of their information under the Privacy Act.

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