Brown-Criscuolo v. Wolfe

601 F. Supp. 2d 441 (2009)

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Brown-Criscuolo v. Wolfe

United States District Court for the District of Connecticut
601 F. Supp. 2d 441 (2009)

  • Written by Sharon Feldman, JD

Facts

Robin Brown-Criscuolo (plaintiff) was a school principal and responsible for overseeing the special-education program. Robert Wolfe (defendant), the school-district superintendent, supervised Brown-Criscuolo. Wolfe and Brown-Criscuolo disagreed about the handling of the special-education referral-and-evaluation process. Brown-Criscuolo took a medical leave. Wolfe became acting principal of Brown-Criscuolo’s school. Brown-Criscuolo’s emails were protected by a password known only to Brown-Criscuolo and the system administrator. While Brown-Criscuolo was on leave, Wolfe accessed Brown-Criscuolo’s computer and emails. Wolfe forwarded to himself and saved on his computer an email containing a letter Brown-Criscuolo had sent to her attorney describing her problems with Wolfe. Under the school district’s acceptable-use policy (AUP), system users had a limited privacy expectation in the contents of their personal files; the system was to be used for educational or professional-development activities; a user’s personal files could be discoverable under state public-records laws; and users were prohibited from attempting to gain unauthorized access to the system, including attempting to log in through another person’s account. Although the AUP provided that routine maintenance and monitoring could lead to discovery of disciplinary-code violations, the system was not routinely monitored. Brown-Criscuolo sued Wolfe for violating the Fourth Amendment by improperly searching and seizing her emails. Wolfe moved for summary judgment, arguing that he accessed Brown-Criscuolo’s email account to review school-related messages.

Rule of Law

Issue

Holding and Reasoning (Squatrito, J.)

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