Daniel v. Cantrell
United States Court of Appeals for the Sixth Circuit
375 F.3d 377 (2004)
- Written by Miller Jozwiak, JD
Facts
Alden Joe Daniel Jr. (plaintiff) was suspected of sexually assaulting underage girls. During the investigation, law-enforcement officials obtained Daniel’s video rental records on the theory that Daniel had been showing pornographic material to the children he was alleged to have assaulted. During later pretrial proceedings, Daniel sought to suppress those video rental records as obtained in violation of the Video Privacy Protection Act of 1988 (VPPA). Before trial, however, Daniel pleaded guilty to various charges. Daniel then sued a litany of defendants, claiming that they had violated the VPPA when they obtained or disclosed his video rental records. These defendants included the parents of Daniel’s alleged victims (who later sued Daniel civilly), those parents’ attorneys, and the law-enforcement officials who obtained and disclosed the records (collectively, the group) (defendants). This group then moved to dismiss the case, which the district court converted to a motion for summary judgment and granted. The district court reasoned that the group could not be subject to liability under the VPPA because it was not a video service provider under the law.
Rule of Law
Issue
Holding and Reasoning (Cudahy, J.)
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