Doe v. Chao
Several individuals sued the Department of Labor’s Office of Worker Compensation Programs for violating the Privacy Act by publishing the social security numbers of claimants seeking benefits for black lung disease. The Privacy Act authorizes lawsuits against government agencies whose violations “have an adverse effect on an individual” and authorizes compensation for actual damages. The statute also provides that “in no case shall a person entitled to recovery receive less than the sum of $1000.” The district court ruled that the statute requires a showing of actual damages, and the court of appeals affirmed, granting summary judgment for the government because none of the individuals had made showing of actual damages.
Question Presented:
Whether, under the Privacy Act, 5 U.S.C. 552a, an individual who has proven a violation of the Privacy Act, but cannot prove actual damages, is automatically entitled to $1000 in damages.




