## Facts

- Michael Leon Seaton, a California prisoner, was serving a lengthy sentence for multiple sexual offenses and kidnapping.
- As Seaton approached potential release, state officials transferred him to a state hospital for evaluation for possible civil commitment under California’s Sexually Violent Predator Act (SVPA).
- The SVPA authorizes indeterminate civil commitment of certain sex offenders based on qualifying convictions, a diagnosed mental disorder, and a likelihood of future sexually violent criminal behavior.
- State mental health officials arranged for two psychologists to review Seaton’s prison and medical records and evaluate him for SVPA criteria.
- The psychologists provided their opinions and supporting data to the county district attorney for use in deciding whether to file an SVPA commitment petition.
- Seaton filed a 42 U.S.C. § 1983 action alleging that officials and psychologists violated a federal constitutional right to informational privacy by permitting access to his records and transmitting evaluation results and supporting information to the district attorney.
- The district court dismissed the complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim, and Seaton appealed.

## Issues

1. Whether a prisoner evaluated for SVPA commitment has a federal constitutional right to informational privacy in prison and medical records that is violated when state officials and evaluators review those records and provide evaluations and supporting information to a prosecutor for SVPA proceedings.
2. If such a right exists, whether it was clearly established so as to permit damages liability under § 1983 (i.e., overcome qualified immunity).

## Decision

- The Ninth Circuit affirmed dismissal for failure to state a claim.
- The court held that the pleaded facts did not show a federal constitutional violation based on the access to and use of Seaton’s records in the SVPA evaluation process and related communications to the district attorney.
- In any event, the court concluded that no clearly established federal law barred the challenged access and disclosures in this context, entitling defendants to qualified immunity from damages.

## Legal Principles

- Any federal constitutional interest in avoiding disclosure of personal information is limited, context dependent, and not precisely defined by Supreme Court precedent.
- In the Ninth Circuit, any recognized privacy interest in medical information is qualified and subject to balancing against legitimate governmental interests.
- Prisoners have a reduced expectation of privacy in institutional and medical records generated and maintained by the state in connection with incarceration and treatment.
- Intra-governmental use and disclosure of records for statutorily authorized public-safety functions—such as SVPA screening and evaluation—generally defeats a claimed constitutional bar absent clearly established law to the contrary.
- Officials are not liable for damages under § 1983 where the asserted constitutional right is not clearly established in the specific setting presented (qualified immunity).

## Conclusion

The Ninth Circuit held that Seaton’s § 1983 complaint did not plausibly allege a federal constitutional privacy violation arising from state psychologists’ review of his prison and medical records and their communication of SVPA evaluation opinions and supporting information to the district attorney, and that any such asserted right was not clearly established.


Seaton v. Mayberg, 610 F.3d 530 (9th Cir. 2010)