Senne v. Village of Palatine, Ill.

Dist. Ct. erred in granting defendant-Village’s motion to dismiss plaintiff’s lawsuit alleging that defendant’s practice of printing personal information such as his name, address, driver’s license number, date of birth, sex, height and weight on printed parking ticket that was placed on plaintiff’s vehicle violated anti-disclosure provisions of Driver’s Privacy Protection Act (DPPA). Instant parking ticket and placement on plaintiff’s vehicle constituted regulated disclosure under DPPA, and plaintiff stated viable cause of action where record failed to indicate how instant disclosed information played any role in effectuating Village’s law enforcement. Ct. rejected defendant’s argument that plaintiff must show that someone actually viewed parking ticket on his vehicle to state claim under DPPA. (Dissent filed.)