United States Eighth Circuit

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Van Zee v. Hanson, 10-1588

In an action alleging that defendant violated plaintiff's Fourteenth Amendment rights by disclosing his juvenile records to an Army recruiter, the dismissal of the complaint is affirmed where: 1) plaintiff had (at least) constructive notice that the district court intended to consider matters outside the complaint when the court, by memorandum to counsel, requested copies of any release forms plaintiff signed when enlisting in the Army; and 2) the court need not determine whether plaintiff had a property interest in the confidentiality of his juvenile records, because he waived any interest he might have had.

Appellate Information

  • Decided 01/18/2011
  • Published 01/18/2011


  • Duane M. Benton


  • United States Eighth Circuit