Patton v. United States
Civil Action No. 2015-0881
| D.D.C. | Jul 19, 2016Background
- Plaintiff Omari H. Patton is a federal prisoner who alleges the Bureau of Prisons (BOP) failed to correct inaccuracies in his Presentence Investigation Report (PSR) in his inmate file and seeks amendment plus $500,000 in damages.
- Patton filed suit invoking the Privacy Act; defendants moved to dismiss under Rule 12(b)(6) and for summary judgment.
- The BOP had exempted its Inmate Central Records System from the Privacy Act’s amendment requirements by regulation (28 C.F.R. § 1.97(a)).
- The court considered controlling D.C. Circuit precedent that limits judicial authority to order amendment of inmate records when the BOP has properly exempted the system.
- The court also addressed that damages claims premised on violations of the exempted regulatory requirements are barred by precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court can order amendment of BOP inmate records under the Privacy Act | Patton contends BOP must correct inaccuracies in his PSR and the court can order amendment | BOP argues its Inmate Central Records System is exempt from the Privacy Act’s amendment provision, so courts cannot order amendment | Court held the BOP exemption prevents ordering amendment of inmate records |
| Whether Patton can recover damages under the Privacy Act for alleged failures to maintain accurate records | Patton seeks $500,000 in damages for harms caused by the alleged inaccuracies | Defendants argue damages claims fail because they rest on regulations and systems exempted from the statute’s requirements | Court held damages claim fails because it is premised on violations of exempting regulations |
| Whether the complaint states a plausible claim under Rule 12(b)(6) | Patton alleges facts showing adverse consequences from the inaccurate PSR | Defendants argue the complaint cannot state a Privacy Act amendment or damages claim given the exemption and controlling precedent | Court dismissed under Rule 12(b)(6) for failure to state a claim |
| Whether BOP satisfied any internal obligations to verify PSR accuracy | Patton asserts BOP failed to correct inaccuracies | Defendants point to BOP’s steps contacting the Probation Office; probation offices are not agencies under the Privacy Act | Court noted BOP took reasonable verification steps and that Probation Offices are not covered by the Privacy Act |
Key Cases Cited
- Skinner v. U.S. Dep't of Justice & Bureau of Prisons, 584 F.3d 1093 (D.C. Cir. 2009) (BOP exemption prevents courts from ordering amendment of inmate records)
- Martinez v. Bureau of Prisons, 444 F.3d 620 (D.C. Cir. 2006) (per curiam) (Privacy Act limitations on remedies for inmate records)
- White v. United States Probation Office, 148 F.3d 1124 (D.C. Cir. 1998) (per curiam) (rules on agency status and Privacy Act applicability)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for plausibility under Rule 12(b)(6))
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must raise right to relief above speculative level)