Matson v. BD. OF EDUC., CITY SCHOOL DIST. OF NY
631 F.3d 57
| 2d Cir. | 2011Background
- Matson, a New York City public school music teacher and conductor, took sick leave from 2003 to 2005 amid an internal inquiry into her absences.
- An SCI investigation concluded Matson abused sick leave and recommended termination; its August 2005 Report disclosed Matson's medical condition, including fibromyalgia/CFS, and was published on the SCI website.
- Disciplinary charges were filed and later withdrawn; Matson suffered a car crash in August 2005 and later sought disability retirement.
- Matson filed a 42 U.S.C. § 1983 privacy claim in 2008, arguing the public disclosure violated her privacy rights by disseminating her medical information.
- The district court dismissed the complaint under Rule 12(b)(6), concluding fibromyalgia/CFS do not implicate a constitutionally protected privacy right and that BOE was not a proper party; this appeal followed.
- The panel affirmed the district court, holding there was no protectable privacy interest in Matson’s conditions and that the BOE issue did not require reversal (with a dissent arguing for a broader privacy protection).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether medical-condition privacy is protected | Matson contends fibromyalgia/CFS are highly private medical information warranting protection. | Defendants contend fibromyalgia/CFS do not create a constitutionally protected privacy interest. | No protected privacy right for fibromyalgia/CFS at issue |
| BOE as proper defendant | BOE remains a proper defendant separate from the City/DOE for disclosure harms. | BOE/DOE not properly suable or intertwined with SCI's actions. | BOE remains potentially liable; district court decision to dismiss BOE reversed in part by the dissent |
| Recusal sua sponte | District Judge should have recused due to prior City service and familial ties. | No statutory or ethical basis shown for recusal. | No sua sponte recusal required |
Key Cases Cited
- Doe v. City of New York, 15 F.3d 264 (2d Cir. 1994) (privacy right to confidentiality of health information)
- O'Connor v. Pierson, 426 F.3d 187 (2d Cir. 2005) (privacy in medical records; limits and case-by-case approach)
- Powell v. Schriver, 175 F.3d 107 (2d Cir. 1999) (privacy interests in sensitive conditions like transsexualism)
- Doe v. City of New York, 15 F.3d 264 (2d Cir. 1994) (see above for Doe; reiterated privacy scope in health matters)
- Rankin v. N.Y. Pub. Library, 1999 WL 1084224 (S.D.N.Y. 1999) (social stigma considerations in privacy context)
- Weixel v. Bd. of Educ. of the City of N.Y., 287 F.3d 138 (2d Cir. 2002) (privacy/discrimination considerations for chronic conditions)