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Doe v. Southeastern Pennsylvania Transportation Authority
United States Court of Appeals for the Third Circuit
72 F.3d 1133 (1995)
Facts
John Doe (plaintiff) worked for the Southeastern Pennsylvania Transportation Authority (SEPTA) (defendant). SEPTA was self-insured and monitored its prescription-drug program for various reasons, including fraud, program costs, and drug abuse. As part of SEPTA’s monitoring of the program, its chief administrative officer, Judith Pierce, reviewed various reports from Rite-Aid, the entity that filled prescriptions through the program. One such report listed employees’ names and their prescriptions. Through this report and follow-up discussions with SEPTA doctors, Pierce discovered that Doe had AIDS. The SEPTA doctors had already known about Doe’s condition through Doe’s voluntary disclosure to them. As part of her review of the program, however, Pierce disclosed the diagnosis to SEPTA’s director of benefits, Jacob Aufschauer. Doe sued SEPTA pursuant to 42 U.S.C. § 1983, alleging that the discovery through the program violated his constitutional right to privacy under the Fourteenth Amendment. A jury found in Doe’s favor and awarded him $125,000 in damages for emotional distress. SEPTA appealed.
Rule of Law
Issue
Holding and Reasoning (Rosenn, J.)
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