Heglund v. City of Grand Rapids, No. 16-3063 (8th Cir. 2017)
Annotate this CasePlaintiff and her husband filed suit against numerous defendants, alleging that police officers had improperly accessed their private information in the State's driver's license database. The Eighth Circuit affirmed the district court's grant of summary judgment for the former Grand Rapids assistant chief of police and Grand Rapids. The court held that plaintiff had Article III standing to bring her Driver's Privacy Protection Act (DPPA), 18 U.S.C. 2721, claim; the doctrine of equitable estoppel did not apply in this case because any delay by the Minnesota Department of Public Safety was not attributable to Grand Rapids or the assistant chief; plaintiff did not make a "mistake" in the ordinary sense of the word when she intentionally sued "John Doe" while knowing that he was not the proper defendant; and thus the amended complaint did not relate back as substituting the assistant chief for John Doe as defendant under Federal Rule of Civil Procedure 15(c).
Court Description: Colloton, Author, with Smith, Chief Judge, and Kelly, Circuit Judge] Civil case - Driver's Privacy Protection Act. Plaintiffs have standing to bring their DPPA claims as they alleged that defendant Scherf had violated DPPA's substantive protections by invading plaintiff Jennifer Heglund's privacy, and the intangible harm associated with an alleged violation of the DPPA's substantive protections is sufficient to establish an injury in fact for standing purposes; the district court did not err in determining plaintiffs' claims were untimely; equitable estopped does not apply as defendant City of Grand Rapids did not engage in any misleading conduct; amended complaint did not relate back as substituting defendant Scherf for a John Doe defendant is not a mistake under Rule 15(c).
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.