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Doe v. Chao
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Doe v. Chao : ウィキペディア英語版
Doe v. Chao

''Doe v. Chao'', 540 U.S. 614 (2004), is a decision by the United States 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 pseudonym), filed for benefits under the federal 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 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 certiorari to resolve the dispute.

抄文引用元・出典: フリー百科事典『 ウィキペディア(Wikipedia)
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