Minda v. United States, No. 15-3964 (2d Cir. 2017)Annotate this Case
Plaintiffs filed suit under 26 U.S.C. 7431 against the IRS, after the IRS sent a report containing plaintiffs' names, social security numbers, and financial information to the wrong person. The government conceded liability and acknowledged that plaintiffs were entitled to $1,000 each in statutory damages for the disclosure of the report. Plaintiffs argued, however, that they were entitled to statutory damages of $1,000 not just for the disclosure of the report but for the disclosure of each item of information contained in the report. Plaintiffs also sought punitive damages. The district court granted the government's motion for summary judgment. The court found no ambiguity in the statute, and held that the statute clearly provided an aggrieved taxpayer $1,000 in statutory damages for ʺeach actʺ of unauthorized disclosure, not for each item of information disclosed. To the extent that there was any doubt, the court explained that it must resolve the matter in favor of the government. In regard to punitive damages, the court agreed with the district court that no reasonable jury could find, on the record presented, that the disclosure resulted from anything other than ordinary negligence. Accordingly, the court affirmed the judgment.