Democracy Partners, LLC v. Project Veritas Action Fund
United States District Court for the District of Columbia
285 F. Supp. 3d 109 (2018)
Facts
Conservative political entity Project Veritas Action Fund (Project Veritas) (defendant) helped Allison Maass (defendant) fabricate an identity so that Democracy Partners, LLC (plaintiff) would hire her as an intern. Democracy Partners, which provided political consulting services to Democratic party candidates, had private offices with around-the-clock security and restricted access. After Maass was hired, she accessed confidential communications and secretly recorded meetings held in the Democracy Partners offices, passing the information to Project Veritas. Democracy Partners learned Maass’s true identity and sued both Maass and Project Veritas for claims including trespass. The complaint, which did not allege actual damages, asserted that any authorization given to Maass to enter its property was invalid because the authorization had been fraudulently induced. The complaint also alleged that Maass’s recording of meetings exceeded the scope of any authorization Democracy Partners had granted Maass to enter its property. The complaint further alleged that Maass had intentionally entered Democracy Partners’ property, interfering with its possessory interest. Maass and Project Veritas moved to dismiss the trespass claim.
Rule of Law
Issue
Holding and Reasoning (Huvelle, J.)
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