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Walker v. Coffey

956 F.3d 163 (2020)

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Walker v. Coffey

United States Court of Appeals for the Third Circuit
956 F.3d 163 (2020)

Facts

When the Pennsylvania Office of the Attorney General charged Carol Lee Walker (plaintiff) with forgery and computer crimes, it assigned Senior Deputy Attorney General Brian Coffey (defendant) as the prosecutor and Special Agent Paul Zimmerer (defendant) as the lead investigator. Coffey and Zimmerer asked Walker’s employer, Pennsylvania State University (Penn), to provide Walker’s emails from her work account. Penn told them that required a subpoena. Coffey and Zimmerer obtained a subpoena but only partially completed the required fields, meaning that the subpoena was legally unenforceable. Nevertheless, when Coffey and Zimmerer provided the subpoena to Penn, Penn’s assistant general counsel instructed a Penn employee to provide Walker’s work emails to Zimmerer. Eventually, the criminal charges against Walker were dismissed. Walker subsequently sued Coffey and Zimmerer, alleging that they had violated the Stored Communications Act (SCA) by gaining access to Penn’s communications system using an invalid subpoena. The district court dismissed the claim, concluding that the SCA did not give Walker a privacy right in her work emails and she therefore lacked a viable claim. Walker appealed.

Rule of Law

Issue

Holding and Reasoning (Restrepo, J.)

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