Moravek v. United States

2008 WL 2383664 (2008)

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Moravek v. United States

United States District Court for the District of South Carolina
2008 WL 2383664 (2008)

Facts

The federal government arrested Steven Moravek (plaintiff) for counterfeiting money and charged him with that crime. Shortly after his arrest, Moravek saw Dr. Carol Denier, a psychotherapist, at a Veterans Affairs hospital run by the federal government (VA hospital) (defendant). During that session, Moravek expressed suicidal thoughts and the desire to kill people who had been involved in his arrest. At that time, Moravek was set to be arraigned about a week later. Denier spoke to the VA hospital’s lawyer, who in turn contacted the United States Attorney’s Office. After the Attorney’s Office learned of the threatening comments, the criminal trial court ordered Moravek to be held pending trial and to undergo a psychiatric examination. Eventually, Moravek pleaded guilty. In response to the VA hospital’s actions, Moravek sued for various privacy-related torts under the Federal Tort Claims Act. Moravek’s claims included breach of confidentiality. Under that law, South Carolina law governed Moravek’s claims. The VA hospital moved for summary judgment.

Rule of Law

Issue

Holding and Reasoning (Norton, J.)

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