Doe v. Chao

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Doe v. Chao
Supreme Court of the United States
Argued December 3, 2003 Decided February 24, 2004
Full case name	Buck Doe v. Elaine L. Chao, Secretary of Labor
Docket no.	02–1377
Citations	540 U.S. 614 (more) 124 S. Ct. 1204; 157 L. Ed. 2d 1122; 2004 U.S. LEXIS 1622; 72 U.S.L.W. 4178; 17 Fla. L. Weekly Fed. S 132; Unemployment Ins. Rep. (CCH) ¶ 17,159B
Case history
Prior	Summary judgment in favor of plaintiff, Doe v. Herman, No. 2:97-cv-00043, 2000 WL 34204432 (W.D. Va. July 24, 2000); reversed sub. nom., Doe v. Chao, 306 F.3d 170 (4th Cir. 2002); cert. granted, 539 U.S. 957 (2003).
Holding
Plaintiffs must prove that some actual damages resulted from a federal agency's intentional or willful violation of the Privacy Act of 1974 in order to qualify for the statutory minimum award of $1000 provided for such a violation under that statute. Fourth Circuit affirmed.
Court membership
Chief Justice William Rehnquist Associate Justices John P. Stevens · Sandra Day O'Connor Antonin Scalia · Anthony Kennedy David Souter · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer
Case opinions
Majority	Souter, joined by Rehnquist, O'Connor, Kennedy, Thomas; Scalia (except for one paragraph and one footnote of the opinion)
Dissent	Ginsburg, joined by Stevens, Breyer
Dissent	Breyer
Laws applied
Privacy Act of 1974, 5 U.S.C. § 552a

Doe v. Chao, 540 U.S. 614 (2004), is a decision by the United States Supreme Court^[1] that interpreted the statutory damages provision of the Privacy Act of 1974.^[2]

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.