Narrative Opinion Summary
This case involves an appeal by Angelo B. Perry against the Bureau of Prisons (BOP), which was initially dismissed by the district court for failing to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii). Perry alleged that the BOP violated his First Amendment right by transferring him based on incorrect prison records. He argued that his complaint should have been assessed under the Privacy Act, 5 U.S.C. § 552a, which permits individuals to sue federal agencies over record-keeping failures that cause adverse outcomes. Perry claimed that the BOP's actions were intentional or willful and resulted in actual damages. The appellate court acknowledged that it had not previously established the necessary elements for a Privacy Act claim but chose to adopt the Ninth Circuit's formulation, which Perry's allegations satisfied. As a result, the appellate court vacated the district court's dismissal and remanded the case for reconsideration under the Privacy Act framework, allowing for further proceedings consistent with this legal theory.
Legal Issues Addressed
Dismissal for Failure to State a Claim under 28 U.S.C. § 1915(e)(2)(B)(ii)subscribe to see similar legal issues
Application: The court initially dismissed Perry's complaint for failing to state a claim under the federal statute governing in forma pauperis proceedings.
Reasoning: Angelo B. Perry appealed the dismissal of his complaint against the Bureau of Prisons (BOP) for failing to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii).
Elements of a Privacy Act Claimsubscribe to see similar legal issues
Application: The court adopted the Ninth Circuit's formulation for a Privacy Act claim, which requires demonstrating inaccurate record maintenance, direct causation of adverse outcomes, intentional or willful failure by the agency, and actual damages.
Reasoning: Perry argued that his complaint met the criteria for a Privacy Act claim, which requires demonstrating that the agency failed to maintain accurate records, which directly caused adverse outcomes, that the failure was intentional or willful, and that actual damages were incurred.
Privacy Act Claims under 5 U.S.C. § 552asubscribe to see similar legal issues
Application: The court recognized Perry's claim as falling under the Privacy Act, which governs the government's management of personal information and allows for lawsuits against federal agencies for record maintenance failures.
Reasoning: Perry contended that the district court incorrectly treated his complaint as a Bivens claim, when it should have been recognized under the Privacy Act, 5 U.S.C. § 552a(g)(1)(C) and (g)(4).
Remand for Reconsideration under Privacy Actsubscribe to see similar legal issues
Application: The appellate court vacated the district court's decision and remanded the case for reconsideration under the correct legal framework of the Privacy Act.
Reasoning: Consequently, the court vacated the district court’s decision and remanded the case for reconsideration under the Privacy Act.