PEARSON V. DODD, US Ct. of Appeal for D.C. Circuit, 1969, 410 F.2d 701 by JohnMValentine


PEARSON V. DODD, US Ct. of Appeal for D.C. Circuit, 1969, 410 F.2d 701 History: District Court granted partial summary judgment to Senator Dodd (appellee), finding liability on a theory of conversion; at the same time, court denied partial summary judgment on invasion of privacy Facts: Two former employees of Senator Dodd, entered his office, w/out his knowing, and took documents, made copies of them, replaced the originals, and gave the copies to defendant Anderson (who knew how they got them); Pearson and Anderson then published the content of the documents Issue(s): Were Defendants liable for conversion from using documents they knew were obtained w/out authorization? Whether or not conversion protects the information gleaned from the documents? Holding: Affirm Dist Court’s denial of summary judgment for invasion of privacy and reverse its grant of summary judgment for conversion Analysis: Most distinctive feature of conversion is its measure of damages, the value of the goods converted Court says not conversion—Dodd was not substantially deprived of his use of them since it was all done at night and they were returned undamaged Information in documents wasn’t literary property, scientific invention, or secret plans for the conduct of commerce Information taken is not property subject to protection by suit of conversion and no conversion of physical contents of files took place

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