Dyer v. Northwest Airlines Corp.
United States District Court for the District of North Dakota
334 F. Supp. 2d 1196 (2004)

- Written by Sean Carroll, JD
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
Issue
Holding and Reasoning (Hovland, C.J.)
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