Van Zee v. Hanson

Joseph Van Zee (plaintiff) signed release forms authorizing disclosure of his juvenile probation and court records to his Army recruiter, and Marilyn Hanson (defendant), a county Clerk of Courts, disclosed those records, prompting the recruiter to cancel his enlistment. Van Zee sued Hanson under § 1983, alleging a constitutional privacy violation; the district court requested copies of the release forms during proceedings and granted Hanson's motion to dismiss, finding no privacy violation given the executed releases. Van Zee appealed, arguing the release forms weren't part of the original pleadings, so the court's reliance on them should have converted Hanson's motion into a summary judgment motion under Rule 12(d), entitling him to respond.