Roberts v. Austin

632 F.2d 1202 (1980)

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Roberts v. Austin

United States Court of Appeals for the Fifth Circuit
632 F.2d 1202 (1980)

Facts

Edward Austin, a state prosecuting attorney for Florida’s Fourth Judicial Circuit (defendant), requested from the Department of Health and Rehabilitative Services (HRS) (defendant) the records of all food-stamp recipients residing in various counties in Florida who received at least $125 per month in food stamps. Although the request was part of an overall fraud investigation, Austin had no basis for believing that any of the individuals who were the subjects of the records had committed fraud. HRS provided the records to Austin. After that, Austin compiled information sheets for each household, which Austin then distributed to local police, who were instructed to conduct investigations to verify the households’ application information. Low-income food-stamp recipients who resided in the affected Florida counties (the recipients) (plaintiffs) sued Austin and HRS, claiming a violation of the recipients’ statutory rights as well as constitutional rights to privacy, freedom from unreasonable search and seizure, and due process. The recipients sought damages and injunctive relief to prevent Austin from demanding and HRS from providing records in the absence of a suspicion of fraud. The district court denied relief, finding that Austin was entitled to the records from HRS as an official “directly connected” with the enforcement of the food-stamp program even if no fraud was suspected. The district court also concluded that the recipients did not have a protected right to privacy in the records. The recipients appealed.

Rule of Law

Issue

Holding and Reasoning (Hatchett, J.)

Concurrence (Hill, J.)

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