Pyle v. Woods

MURPHY, Circuit Judge.

I. Introduction

After Detective James Woods accessed a state database containing the prescription drug records of Plaintiffs Ryan Pyle and Marlon Jones, Pyle and Jones brought separate lawsuits pursuant to 42 U.S.C. § 1983, each challenging Defendants’ conduct as violative of the Fourth Amendment and the Fair Credit Reporting Act (“FCRA”). In both suits, the district court dismissed the claims against Defendant Woods, concluding Woods was entitled to qualified immunity because the law governing warrantless access to prescription drug information by law enforcement was not…