Transportation – DPPA

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Transportation – DPPA

It violates the Driver’s Privacy Protection Act for a municipality to include personal information on a parking citation.

“We hold that the DPPA’s general rule of non-disclosure of personal information held in motor vehicle records and its overarching purpose of privacy protection must inform a proper understanding of the other provisions of the statute. Accordingly, we hold that any disclosure must comply with those legitimate uses of information identified in the statutory exceptions. With these principles in mind, we hold that the Village’s placement of protected personal information in view of the public constituted a disclosure regulated by the statute, regardless of whether Mr. Senne can establish that anyone actually viewed it. Furthermore, because Mr. Senne has articulated a plausible claim that the Village’s actions failed to fulfill its statutory duties, the case should not have been dismissed.”

Reversed and Remanded.

10-3243 Senne v. Village of Palatine

Appeal from the United States District Court for the Northern District of Illinois, Kennelly, J., Ripple, J.

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