Maydak v. United States
394 U.S. App. D.C. 22
| D.C. Cir. | 2010Background
- This case involves Trust Fund reimbursements and Privacy Act claims arising from BOP’s retention and review of duplicate inmate photos; the Trust Fund is managed by the U.S. government for the benefit of federal inmates and funds use is restricted to inmate-related programs.
- Appellants Lee, Maydak, and Smith filed suit in 1997 alleging misuses of Trust Fund monies and Privacy Act violations surrounding the retention and review of duplicate photos at multiple BOP facilities.
- The District Court granted summary judgments in favor of the Government on Privacy Act claims and Trust Fund claims; the court held no nationwide discovery was warranted and that reimbursements were sufficient.
- On appeal, the panel vacated the District Court’s judgment on Trust Fund claims due to mootness and lacking standing, but affirmed the Privacy Act judgment to the extent discussed, applying the intentional or willful standard.
- The court ultimately addresses mootness/standing for Trust Fund claims and whether the Government acted intentionally or willfully under the Privacy Act, remanding or affirming as appropriate.
- Relevant authorities were considered, including Maydak I (on system-of-records analysis) and privacy/standing jurisprudence such as Summers, DeFunis, Lujan, Waters, and Albright.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Trust Fund claims are moot and lack standing. | Maydak argues standing remains to pursue Trust Fund refunds. | Government contends claims moot since appellants are released from custody. | Trust Fund claims are moot; no standing to pursue further relief. |
| Whether BOP practices constitute a Privacy Act system of records. | Appellants contend duplicate photos are a system of records retrievable by personal identifiers. | District Court correctly held no system of records or, if assumed, intent must be shown. | Assuming system of records, not shown to be intentional or willful. |
| Whether the Privacy Act | Appellants argue intentionality can be inferred from notice and continued retention. | Government shows legitimate purposes and lack of willfulness. | Appellants failed to show intentional or willful violation; summary judgment upheld. |
| Whether the district court erred in denying broad discovery on Trust Fund; and related relief requests. | Appellants sought nationwide discovery of misuses. | Court correctly limited discovery. | Remains unresolved as mootness/standing resolved; relevance limited. |
Key Cases Cited
- Maydak v. United States, 363 F.3d 512 (D.C.Cir. 2004) (whether BOP photo file constitutes a system of records; remand guidance on retrieval by identifiers)
- Albright v. United States, 732 F.2d 181 (D.C.Cir. 1984) (intentional or willful standard for Privacy Act damages requires egregious conduct)
- Henke v. United States Dept. of Commerce, 83 F.3d 1453 (D.C.Cir. 1996) (retrieval by personal identifier is needed to create a system of records)
- Summers v. Earth Island Institute, 555 U.S. 488 (S. Ct. 2009) (standing cannot be maintained for policy challenges after settlement of specific action)
- DeFunis v. Odegaard, 416 U.S. 312 (S. Ct. 1974) (mootness where prospective student’s action becomes moot before full review)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (S. Ct. 1992) (standing requirements: injury, causation, redressability)