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Dyer v. Northwest Airlines Corp.

United States District Court for the District of North Dakota

334 F. Supp. 2d 1196 (2004)

Facts

The National Aeronautical and Space Administration (NASA) asked Northwest Airlines Corporation (Northwest) (defendant) to turn over certain passenger information to allow NASA to study ways to make air travel safer. Northwest complied and turned over certain passenger records that included passengers’ names, flight numbers, and credit-card information, among other data. Edwin Dyer (plaintiff) sued Northwest, alleging this disclosure violated the Electronic Communications Privacy Act (ECPA). Northwest argued that it did not provide electronic communication services and thus could not be liable under the ECPA.

Rule of Law

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Issue

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Holding and Reasoning (Hovland, C.J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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