Seaton v. Mayberg
United States Court of Appeals for the Ninth Circuit
610 F.3d 530 (2010)

- Written by Miller Jozwiak, JD
Facts
Michael Leon Seaton (plaintiff) was convicted of various crimes related to a sexual assault. Although Seaton was initially sentenced to 42 years in prison, his sentence was gradually reduced. After Seaton served 16 years, state officials had him transferred to a state hospital for evaluation ahead of a possible civil commitment. The state official who ran the hospital had two psychologists (collectively, state officials) (defendants) perform the evaluation. Under California law, officials could have sex offenders civilly committed for indeterminate terms subject to yearly evaluations. To do so, officials had to comply with numerous procedural requirements. Among them were evaluations by two different psychiatrists or psychologists. The records of those evaluations were then made available to a county attorney, who would review the documents and determine whether to bring a petition for commitment. This could lead to a jury trial and possible civil commitment. The two psychologists who reviewed Seaton’s medical records recommended civil commitment for Seaton. The psychologists gave their evaluations and the documentation to a district attorney, who decided to petition for commitment. While Seaton was held pending trial, he brought a § 1983 action against the state officials for (among other things) violating his right to privacy by viewing his medical records and sharing them with the district attorney.
Rule of Law
Issue
Holding and Reasoning (Kleinfeld, J.)
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