Patel v. Jaddou, No. 23-5867 (6th Cir. 2024)
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The case involves Indian citizens Sanket and Nehaben Patel who sued the Director of U.S. Citizenship and Immigration Services, Ur Jaddou, under the Administrative Procedure Act for unreasonable delay in processing their applications for U visas. After their visas were granted, the Director moved to dismiss the case for mootness and attached an exhibit showing the applications' approval. The Director then realized she had not filed the exhibit under seal, violating the rule prohibiting the disclosure of information relating to noncitizens who are U visa applicants and recipients. The Patels sought civil penalties for the disclosure of their personal information. The district court dismissed the case and denied the Patels' motion for civil penalties, stating that any disclosure was not willful.
The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court held that the Director's disclosure of the Patels' visa application status was not "willful" under 8 U.S.C. § 1367(c). The court reasoned that the term "willful" refers to actions that are intentional or knowing, as opposed to accidental. The court noted that the Director realized her mistake in not filing the exhibit under seal, promptly contacted the court to seal the exhibit, and the information disclosed was already revealed in the Patels’ unsealed complaint. Therefore, the disclosure was not considered willful but at most amounted to negligence.
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