UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
GARY W. WINTERS,
Plaintiff,
v. Civil Action No. 25 - 1314 (LLA)
DEPARTMENT OF THE ARMY,
Defendant.
MEMORANDUM OPINION AND ORDER
Plaintiff Gary W. Winters sues the U.S. Department of the Army, alleging that the Army
violated the Privacy Act, 5 U.S.C. § 552a, by disclosing his personnel records. ECF No. 2. The
Army has moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). ECF
No. 8. For the following reasons, the court grants the motion as it concerns Mr. Winters’s request
for injunctive relief but denies the remainder of the motion.
I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY
In resolving the Army’s motion to dismiss, the court accepts the following factual
allegations as true. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Mr. Winters served in the Army
for nearly a decade before he was honorably discharged in 2020. ECF No. 2 ¶¶ 15-16. In
November 2023, Mr. Winters began dating Morgan Pasewicz. Id. ¶¶ 17, 19. The pair ended their
“tumultuous relationship” in February 2024. Id. ¶ 20. In May, they both filed for domestic
violence protective orders against each other in state court in North Carolina. Id. ¶ 21. That court
held a hearing on the cross-complaints the following month. Id. ¶¶ 22, 24, 29; see ECF No. 2,
Ex. 1 (June 24, 2024 Hr’g Tr. (“Tr.”)).
At the hearing, Ms. Pasewicz testified, as relevant here, about “accessing” Mr. Winters’s
“military records,” ECF No. 2, Ex. 1, at 15 (Tr. 60:1-10), including a headshot of Mr. Winters in
his military uniform, id. at 7 (Tr. 28:9-14); see ECF No. 2, Ex. 2 (photograph). Ms. Pasewicz
described the photo as an “unclassified record,” ECF No. 2, Ex. 1, at 7 (Tr. 28:4), that her new
boyfriend, Michael Chambers, had requested from a friend in the Army, Sergeant Thomas Dines,
“who is a Special Forces active duty man,” id. at 15 (Tr. 60:7-9); see id. at 8 (Tr. 29:19-20).
Mr. Chambers and Sergeant Dines wanted to access Mr. Winters’s files to verify whether
Mr. Winters had been in the Army Special Forces, “because they suspected that he was not.” Id.
at 7 (Tr. 28:4-8). According to Ms. Pasewicz, Sergeant Dines “went through the proper channels
to get the records.” Id. at 8 (Tr. 29:19-21). In March 2024, Ms. Pasewicz texted the photograph
to Mr. Winters, id. at 7-8 (Tr. 27:15-28:8), alongside messages accusing him of “stolen valor,” id.
at 8 (Tr. 29:3), and calling him a “fucking coward and a liar,” id. (Tr. 32:3-5). Ms. Pasewicz
testified that she “decided to call [Mr. Winters] out” for “not being Special Forces” because she
“thought” it “would embarrass him enough to stop contacting” her. Id. at 16 (Tr. 61:11-13).
At the same hearing, Mr. Winters testified that he had spent his last seven years in the
Army in the “first Special Forces Group, active duty.” Id. at 17 (Tr. 66:4-5). He stated that he
never misrepresented his military service to Ms. Pasewicz and that the two did not “really speak
about the military.” Id. (Tr. 67:14-15). When asked about the photograph, Mr. Winters testified
that “[s]omeone intentionally and illegally took a picture of[f] a . . . federal government system
that was not done through proper channels. . . . That person intentionally and
willingly . . . violated the Uniform Code of Military Justice to pull that from a [Public Affairs
Office] server.” Id. at 20 (Tr. 78:11-17). He continued, “[Ms. Pasewicz] also told me that she has
various other military records[] but refused to disclose what they were.” Id. (Tr. 78:17-19).
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At the conclusion of the hearing, the state court judge entered the requested protective
orders as to both Mr. Winters and Ms. Pasewicz. Id. at 31 (Tr. 121:7-122:8). Mr. Winters
thereafter lodged a complaint with the Army Inspector General about Sergeant Dines’s “unlawful
dissemination” of his personnel records. ECF No. 2 ¶ 43. The Army investigated the matter,
found that Mr. Winters’s allegations were “substantiated,” and “subsequently disciplined”
Sergeant Dines. Id. ¶¶ 44-45.
In April 2025, Mr. Winters filed this suit, alleging that the Army had violated the Privacy
Act when Sergeant Dines disclosed his personnel records to Mr. Chambers. Id. ¶¶ 48-49, 52-53,
58-60. In December, the Army moved to dismiss under Rules 12(b)(1) and 12(b)(6). ECF No. 8.
The motion is fully briefed. ECF Nos. 8, 9, 11.
II. LEGAL STANDARDS
A. Federal Rule of Civil Procedure 12(b)(1)
“Federal courts are courts of limited jurisdiction,” and it is generally presumed that “a cause
lies outside [of] this limited jurisdiction.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S.
375, 377 (1994). Under Federal Rule of Civil Procedure 12(b)(1), the court must dismiss an action
unless the plaintiff can establish, by a preponderance of the evidence, that the court possesses
subject-matter jurisdiction. Green v. Stuyvesant, 505 F. Supp. 2d 176, 177-78 (D.D.C. 2007). In
reviewing a Rule 12(b)(1) motion, the court must “assume the truth of all material factual
allegations in the complaint and ‘construe the complaint liberally, granting [the] plaintiff the
benefit of all inferences that can be derived from the facts alleged.’” Am. Nat’l Ins. Co. v. Fed.
Deposit Ins. Corp., 642 F.3d 1137, 1139 (D.C. Cir. 2011) (quoting Thomas v. Principi, 394 F.3d
970, 972 (D.C. Cir. 2005)). The court “is not limited to the allegations set forth in the complaint”
and “‘may consider materials outside the pleadings.’” Morrow v. United States, 723 F. Supp. 2d
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71, 76 (D.D.C. 2010) (quoting Jerome Stevens Pharms. v. Food & Drug Admin., 402 F.3d 1249,
1253 (D.C. Cir. 2005)).
B. Federal Rule of Civil Procedure 12(b)(6)
Under Rule 12(b)(6), the court will dismiss a complaint that does not “contain sufficient
factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556
U.S. at 678 (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial
plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable
inference that the defendant is liable for the misconduct alleged.” Id. In evaluating a motion under
Rule 12(b)(6), a court accepts all well-pleaded factual allegations in the complaint as true. See
Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam); see also Atherton v. D.C. Off. of Mayor,
567 F.3d 672, 681 (D.C. Cir. 2009). Although the plausibility standard does not require “detailed
factual allegations,” it “requires more than labels and conclusions, and a formulaic recitation of
the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. Nor will “‘naked
assertion[s]’ devoid of ‘further factual enhancement’” suffice. Iqbal, 556 U.S. at 678 (alteration
in original) (quoting Twombly, 550 U.S. at 557). In determining whether a complaint fails to state
a claim, a court may consider only the facts alleged in the complaint and “any documents either
attached to or incorporated in the complaint and matters of which [the court] may take judicial
notice.” N. Am. Butterfly Ass’n v. Wolf, 977 F.3d 1244, 1249 (D.C. Cir. 2020) (alteration in
original) (quoting Hurd v. District of Columbia, 864 F.3d 671, 678 (D.C. Cir. 2017)).
III. DISCUSSION
The Privacy Act prohibits an agency from improperly disclosing “any record which is
contained in a system of records.” 5 U.S.C. § 552a(b). “The civil remedies provision of the
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Privacy Act provides that, for any ‘intentional or willful’ refusal or failure to comply with the Act,
the United States shall be liable for ‘actual damages sustained by the individual as a result of the
refusal or failure, but in no case shall a person entitled to recovery receive less than the sum of
$1,000.’” Fed. Aviation Admin. v. Cooper, 566 U.S. 284, 291 (2012) (quoting 5 U.S.C.
§ 552a(g)(4)(A)); see 5 U.S.C. § 552a(g)(1)(D). The Army argues that Mr. Winters’s claim must
be dismissed because Mr. Winters has not shown that the alleged disclosure: (1) was of a record
“contained in a system of records,” 5 U.S.C. § 552a(b); (2) was “intentional or willful,” id.
§ 552a(g)(4); or (3) resulted in “actual damages,” id. § 552a(g)(4)(A). ECF No. 8, at 9-17.1 The
court considers each argument in turn.
A. “System of Records”
The Privacy Act defines “the term ‘system of records’ [as] a group of any records under
the control of any agency from which information is retrieved by the name of the individual or by
some identifying number, symbol, or other identifying particular assigned to the individual.”
5 U.S.C. § 552a(a)(5). “A system of records exists only if the information contained within the
body of material is both retrievable by personal identifier and actually retrieved by personal
identifier.” Paige v. Drug Enf’t Admin., 665 F.3d 1355, 1359 (D.C. Cir. 2012) (quoting Maydak
v. United States, 630 F.3d 166, 178 (D.C. Cir. 2010)).
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The Army further argues that Mr. Winters cannot seek injunctive relief in the form of expungement of his records because he proceeds under Subsection 552a(g)(1)(D) and, in any event, has not exhausted his administrative remedies under Subsection 552a(d). ECF No. 8, at 7-8. Mr. Winters “concedes that [the Army] is correct in this regard.” ECF No. 9, at 9 n.1. The court accepts the concession. “To the extent that [a plaintiff] seeks an injunction compelling [an agency] to amend or expunge protected information, [his] failure to exhaust administrative remedies bars those claims.” Jacobs v. Nat’l Sec. Agency, No. 19-CV-3439, 2019 WL 7168626, at *2 (D.D.C. Dec. 24, 2019) (citing Haase v. Sessions, 893 F.2d 370, 375 (D.C. Cir. 1990)). Accordingly, the court will dismiss Mr. Winters’s request for injunctive relief.
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In his complaint, Mr. Winters alleges that his personnel records were accessed from his
“Official Military Personnel File,” which is maintained by the Army in a system of records. ECF
No. 2 ¶¶ 24, 48, 52. The Army raises two arguments that Mr. Winters has not established that his
personnel records were pulled from a “system of records” under Section 552a(b), warranting
dismissal under Rule 12(b)(6). ECF No. 8, at 13. Neither persuades the court.
First, the Army contends that Mr. Winters’s allegation that the records came from his
Official Military Personnel File contradicts his testimony from the North Carolina court hearing,
where Mr. Winters stated that the photograph came from an Army Public Affairs Office server.
ECF No. 8, at 2-3 (citing ECF No. 2, Ex. 1, at 20 (Tr. 78:17)). In the Army’s view, this
inconsistency is fatal because “a Public Affairs photo [is] stored on a unit repository rather than
an identifier-retrieved personnel record.” Id. at 13. But the court must credit the allegations in
Mr. Winters’s complaint, in which Mr. Winters contends that the photograph was pulled from his
“Official Military Personnel File,” ECF No. 2 ¶ 24—which the Army does not deny is a “system
of records” under the Privacy Act, see generally ECF No. 8. As Mr. Winters explains, the
photograph could have come from either his Official Military Personnel File or an Army Public
Affairs Office server, ECF No. 9, at 18 n.2, and, at the pleading stage, “Mr. Winters can ‘hardly
be expected to know the full details behind [the] improper disclosure,’” id. at 18 (quoting Feldman
v. Cent. Intel. Agency, 797 F. Supp. 2d 29, 41 (D.D.C. 2011)); see Kelley v. Fed. Bureau of
Investigation, 67 F. Supp. 3d 240, 265 (D.D.C. 2014) (rejecting the defendant’s argument in a
motion to dismiss “that the disclosed information could have come from sources other than a
system of records,” and explaining that “[w]hile plaintiffs will need to amass sufficient evidence
to meet their burden of proof as the case proceeds, they need not do so at the pleading stage”).
Accordingly, by plausibly alleging that the photograph was accessed from his Official Military
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Personnel File, Mr. Winters has sufficiently alleged that records were accessed from a “system of
records” under the Privacy Act.
Additionally, even if the photograph was not accessed from Mr. Winters’s Official Military
Personnel File, Mr. Winters plausibly alleges that Sergeant Dines accessed other records from his
Official Military Personnel File. ECF No. 2 ¶¶ 24, 29, 33, 37. In her testimony, Ms. Pasewicz
referred to “records” (plural) when explaining what Sergeant Dines had requested. ECF No. 2,
Ex. 1, at 8 (Tr. 29:21), 15 (Tr. 60:8, 10). Throughout his complaint, Mr. Winters links these
records to his Official Military Personnel File. ECF No. 2 ¶¶ 24, 29, 37, 42-44, 49, 52-54, 56-57,
60. Mr. Winters further alleges that the Army Inspector General “investigat[ed]” and
“substantiated” his claims of improper access of his Official Military Personnel File. Id. ¶¶ 44-45.
Given the Army’s failure to contest that Mr. Winters’s Official Military Personnel File is contained
in a “system of records,” Mr. Winters’s allegations about the non-photograph records also
withstand the Army’s motion to dismiss.
Second, the Army argues that Mr. Winters does not “plausibly allege that the disclosure
resulted from an actual identifier-based retrieval,” meaning that he “pleads no facts that anyone
queried [his] name or personal identifiers in a [personnel] system of records.” ECF No. 8, at 13
(internal quotation marks omitted). But Mr. Winters alleges that the disclosed personnel records
were “contained in a system of records,” ECF No. 2 ¶ 48, and “one can infer that [personnel]
records would include identifying information” and “be ‘retrieved by the name of the individual’
or by some other identifier,” Lombrano v. Dep’t of the Air Force, No. 21-CV-872, 2022 WL
392308, at *3 n.1 (D.D.C. Feb. 9, 2022) (quoting 5 U.S.C. § 552a(a)(5)); see Krieger v. U.S. Dep’t
of Just., 529 F. Supp. 2d 29, 42 (D.D.C. 2008) (observing that the plaintiff’s official personnel file
was “a record maintained within a system of records”). Again, “[w]hile [Mr. Winters] will need
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to amass sufficient evidence to meet [his] burden of proof as the case proceeds,” he has met his
minimal burden at the pleading stage. Kelley, 67 F. Supp. 3d at 265.
B. “Intentional or Willful”
Not “every affirmative or negligent action that might be said technically to violate the
Privacy Act’s provisions” is redressable under Subsection 552a(g)(4). Maydak, 630 F.3d at 180.
Instead, the agency’s violation must have been “intentional or willful.” 5 U.S.C. § 552a(g)(4).
Accordingly, a plaintiff must generally show that the agency’s violation was: (1) “so patently
egregious and unlawful that anyone undertaking the conduct should have known it unlawful,”
(2) “somewhat greater than gross negligence,” (3) “committed without grounds for believing [it]
to be lawful, or” (4) “in flagrant disregard of others’ rights under the Act.” Maydak, 630 F.3d
at 180.
The Army argues that Mr. Winters cannot satisfy the “intentional or willful” standard
because Sergeant Dines was acting “in direct contravention of Army policy” and “purely personal,
unauthorized conduct by an employee” cannot be attributed to the agency. ECF No. 8, at 9.2 In
the Army’s view, “to be liable for a Privacy Act violation allegedly committed by one of its
employees, the responsible [Army] employee must have been acting within the scope of his or her
employment.” ECF No. 11, at 11 (quoting Convertino v. U.S. Dep’t of Just., 769 F. Supp. 2d 139,
147 (D.D.C. 2011), rev’d on other grounds, 684 F.3d 93 (D.C. Cir. 2012)). Mr. Winters responds
2
The Army frames this as an argument under Rule 12(b)(1), arguing that by failing to “establish an intentional or willful agency disclosure,” ECF No. 8, at 12, Mr. Winters cannot show that his claim falls within the Privacy Act’s waiver of sovereign immunity, id. at 4. Whether the court considers the Army’s argument under Rule 12(b)(1) or Rule 12(b)(6), the court reaches the same result.
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that unlawful disclosures by “rogue [agency] employees” are not immune from liability under the
Privacy Act. ECF No. 9, at 12. Mr. Winters has the better argument.
To begin, courts in this Circuit have allowed complaints to proceed to discovery when the
action that allegedly violated the Privacy Act was part of a personal vendetta rather than an official
agency policy. For example, in Feldman, the court found sufficient intentionality or willfulness
to withstand a motion to dismiss where the plaintiff alleged that his “rivals . . . persecuted him by
ginning up a misconduct investigation against him and then leaking details of that investigation in
violation of the Privacy Act.” 797 F. Supp. 2d at 42. In Tolbert-Smith v. Chu, 714 F. Supp. 2d 37
(D.D.C. 2010), the court reached the same conclusion based on the plaintiff’s allegation that
agency personnel “placed records referring and relating to her disability on a [public] server . . . to
retaliate against her for filing an administrative complaint.” Id. at 43. And in Toolasprashad v.
Bureau of Prisons, 286 F.3d 576 (D.C. Cir. 2002), the D.C. Circuit concluded that the plaintiff’s
allegation that agency staff “fabricated and falsified” information satisfied the Privacy Act’s
requirement of intentional or willful conduct at the motion-to-dismiss stage. Id. at 584. If the
Army were correct that the Privacy Act contained a strict scope-of-employment rule, these cases
undoubtedly would have come out differently, as the agencies at issue would have disavowed the
conduct of their rogue employees.
Against these cases, the Army cites Convertino, in which the court granted the defendants’
motion for summary judgment because the plaintiff, despite his “monumental effort,” could not
identify the agency employee responsible for the disclosure. 769 F. Supp. 2d at 144; see id.
at 145-46. The plaintiff alleged that “an unknown person or persons at [the U.S. Department of
Justice (“DOJ”) had] disclosed details from his [Office of Professional Responsibility] referral to
[a reporter]” in violation of the Privacy Act. Id. at 141-42. While this allegation was sufficient to
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withstand a motion to dismiss, id. at 142, the court determined that, at summary judgment, the
plaintiff needed to “know the leaker’s identity” because, without it, “no reasonable fact-finder
could find that DOJ acted willfully or intentionally with regard to any leak in th[e] case,” id. at 146.
The court went on to explain that “[p]art of the reason [the plaintiff] has to know the leaker’s
identity . . . is that without it, he cannot show that the DOJ employee who allegedly leaked
information . . . was acting within the scope of his or her DOJ employment at the time of the leak.”
Id. at 147. The Army reads this sentence as immunizing agencies from the actions of rogue
employees, ECF No. 11, at 6, but it could just as well be read to mean that the plaintiff needed to
show that the leaker was a DOJ employee at the time of the leak, as opposed to a former employee
whose conduct could not be attributed to the agency.3 In any event, the summary judgment posture
of Convertino is alone sufficient to distinguish it from this case.
C. “Actual Damages”
To “recover a guaranteed minimum award of $1,000 for violations of the [Privacy] Act,”
a plaintiff must “prove at least some ‘actual damages.’” Cooper, 566 U.S. at 295 (quoting Doe v.
Chao, 540 U.S. 614, 627 (2004)). A “plaintiff seeking monetary damages for an agency’s
improper disclosure must establish not only that he was ‘adversely affected’ by the improper
disclosure, but also that he suffered ‘some harm for which damages can reasonably be assessed.’”
3
The latter understanding is consistent with the remainder of the court’s opinion, in which the court rejected the plaintiff’s claim that a particular DOJ employee was the leaker based on evidence that the employee “had access to the information at issue” and “did not like” the plaintiff. Convertino, 769 F. Supp. 2d at 149; see id. at 148 (explaining that the plaintiff “must show that [the suspect] actually did leak the information”; otherwise, the plaintiff could “circumvent[] the Act’s” intentional or willful requirement “simply by proving a blackened heart and an opportunity to violate the Act”). This analysis would not have been necessary if a disclosure motivated by personal animus placed an employee’s actions beyond the scope of his employment.
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Mulhern v. Gates, 525 F. Supp. 2d 174, 181-82 (D.D.C. 2007) (quoting Chao, 540 U.S. at 621).
The Privacy Act does not authorize recovery for “nonpecuniary mental and emotional harm,”
Cooper, 566 U.S. at 302, but instead is “limited to proven pecuniary or economic harm,” id. at 299.
Mr. Winters alleges that as a result of Sergeant Dines’s disclosure to Ms. Pasewicz, he has
suffered “profound and severe anxiety” that has “required [him] to seek further mental health care
and counseling, costing him thousands of dollars to this point and necessitating further care for a[]
yet unknown but certainly substantial period of time.” ECF No. 2 ¶¶ 54-55. The Army argues
that Mr. Winters has not sufficiently alleged actual damages because his “only asserted ‘adverse
effect’ . . . is that he allegedly ‘spent thousands of dollars’ on mental-health treatment,” which,
according to the Army, was not “proximately caused by the alleged [disclosure].” ECF No. 8,
at 14-15 (citation omitted).4 Again, the Army demands too much at the pleading stage.
Mr. Winters plausibly traces the alleged disclosure to an adverse effect: Ms. Pasewicz’s use of the
disclosed records to, in her words, “embarrass” him, ECF No. 2, Ex. 1, at 16 (Tr. 61:13), which
“caused [him] profound and severe anxiety,” ECF No. 2 ¶ 54. Mr. Winters then plausibly ties that
adverse effect to a pecuniary loss: “thousands of dollars” spent on “further mental health care and
counseling.” ECF No. 2 ¶ 55; see Hill v. U.S. Dep’t of Def., 70 F. Supp. 3d 17, 21 (D.D.C. 2014)
(“Direct out-of-pocket expenses, such as payment for medical services, are the very definition of
pecuniary losses.”). That is sufficient at this point in the proceedings. See Hill, 70 F. Supp. 3d
4
The Army raises this argument under both Rules 12(b)(1) and 12(b)(6). ECF No. 8, at 17 (“Where, as here, the complaint pleads no facts . . . to verify that any alleged expenditure for mental health treatment was caused by the alleged Privacy Act violation rather than [Mr. Winters and Ms. Pasewicz’s relationship troubles] . . . , the plaintiff has not carried his jurisdictional burden under the sovereign’s strictly construed waiver nor plausibly pled the elements of a [S]ection 552a(g)(1)(D) claim.”). The court reaches the same result under either rule. See supra n.2.
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at 22; Lombrano, 2022 WL 392308, at *6 (“To state a claim for relief under the Privacy Act, it is
enough to plausibly [plead] ‘some pecuniary harm, no matter how slight.’” (quoting Cooper, 566
U.S. at 296)).
The Army also contends that Mr. Winters’s “pre-existing mental health issues” and other
“extreme stressors” destroy the “requisite causation” by way of Ms. Pasewicz’s “intervening,
private-party conduct.” ECF No. 8, at 15-16; see, e.g., ECF No. 2 ¶ 41 (alleging that Mr. Winters
had discussed his mental health, among other things, with Ms. Pasewicz during their relationship);
ECF No. 2 ¶ 20 (“Mr. Winters and Ms. Pasewicz . . . had a tumultuous relationship.”); ECF No. 2
Ex. 1, at 17-18 (Tr. 67:16-70:6) (similar). But “[a] complaint survives a motion to dismiss even
‘[i]f there are two alternative explanations, one advanced by [the] defendant and the other
advanced by [the] plaintiff, both of which are plausible.’” VoteVets Action Fund v. U.S. Dep’t of
Veterans Affs., 992 F.3d 1097, 1104 (D.C. Cir. 2021) (alterations in original) (quoting Banneker
Ventures, LLC v. Graham, 798 F.3d 1119, 1129 (D.C. Cir. 2015)). The court’s “role is not to
speculate about which [one is] likely to be proved after discovery.” Id. at 1106 (quoting Harris v.
D.C. Water & Sewer Auth., 791 F.3d 65, 70 (D.C. Cir. 2015)).
IV. CONCLUSION
For the foregoing reasons, it is hereby ORDERED that Defendant’s Motion to Dismiss,
ECF No. 8, is GRANTED to the extent that Plaintiff’s request for injunctive relief, ECF No. 2,
at 8, is DISMISSED with prejudice, but the motion is otherwise DENIED. Defendant shall file
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an answer to Plaintiff’s Complaint, ECF No. 2, on or before October 8, 2026, see Fed. R. Civ.
P. 12(a)(4)(A).
SO ORDERED.
LOREN L. ALIKHAN
United States District Judge
Date: September 24, 2026
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