Neal v. Fairfax County Police

CourtSupreme Court of Virginia
DecidedOctober 22, 2020
Docket191127
StatusPublished

This text of Neal v. Fairfax County Police (Neal v. Fairfax County Police) is published on Counsel Stack Legal Research, covering Supreme Court of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Neal v. Fairfax County Police, (Va. 2020).

Opinion

PRESENT: Lemons, C.J., Mims, Powell, Kelsey, McCullough, and Chafin, JJ., and Millette, S.J.

HARRISON NEAL

v. Record No. 191127

FAIRFAX COUNTY POLICE DEPARTMENT, ET AL. OPINION BY JUSTICE STEPHEN R. McCULLOUGH October 22, 2020 FAIRFAX COUNTY POLICE DEPARTMENT, ET AL.

v. Record No. 191129

FROM THE CIRCUIT COURT OF FAIRFAX COUNTY Robert J. Smith, Judge

The Fairfax County Police Department (“Police Department”) appeals from an injunction

that prohibits it from passively collecting, storing, and using license plate and related data

through its Automated License Plate Recognition (“ALPR”) system. Among other things, the

Police Department contends that the circuit court erred in concluding that the ALPR system

satisfies the definition of an “information system” under the Government Data Collection and

Dissemination Practices Act, Code §§ 2.2-3800 through -3809 (“Data Act”). Neal separately

appeals the circuit court’s award of attorney’s fees, contending the circuit court erred in reducing

the fees sought by his attorneys. App. 2089. We agree with the Police Department that the

ALPR system does not constitute an “information system” within the intendment of the Data Act

and we, therefore, reverse the decision below. BACKGROUND

I. THE ALPR SYSTEM.

The Police Department’s ALPR system uses cameras that capture images of passing

vehicles’ license plates. The cameras can be stationary or mounted on a police vehicle. Once

the camera captures a license plate image it converts that image into an alpha-numeric

combination. In order to access that alpha-numeric combination and associated data, an officer

of the Police Department must specifically log on to the ALPR software program. Logging on to

the ALPR software program requires a unique log-in credential and password. Only officers

who have completed the required training can gain access to the software. The Police

Department employs the ALPR system for “active” and “passive” uses.

“Active” use involves checking the license plates that are scanned against a “hot list.”

The Virginia State Police publishes this “hot list” twice daily. The list consists of all active

stolen license plates and vehicles from two databases, the National Crime Information Center

(“NCIC”) and Virginia Criminal Information Network (“VCIN”). The hot list also contains

license plates associated with suspected criminal activity, such as abductions. The hot list is

available to authorized law enforcement personnel who can access it through a secure website.

The hot list can be imported into the ALPR system either automatically through a server or

manually by the end user. The end user may also manually enter a license plate into the ALPR

system along with a notation regarding the reason for the entry, for example a stolen vehicle.

While scanning license plates, the ALPR software alerts the operator when it detects a

potential stolen vehicle or license plate. According to a Standard Operating Procedure (“SOP”)

developed by the Police Department, “[a]n alarm is NOT conclusive confirmation that a license

plate or vehicle is wanted, but an indicator that additional investigation is warranted.” If the

2 ALPR system alerts, the officer is instructed to visually verify the license plate, to make sure it is

from the correct state and displays the same characters as the ones on the screen. The SOP then

instructs the officer to make sure the hot list is still active by checking the NCIC/VCIN

databases, either by running the information in a search on the computer in the car or by a voice

request. The SOP further states that “[s]tolen vehicle or license plate responses from

NCIC/VCIN shall be confirmed by Teletype in accordance with established procedures as soon

as practical.” Additionally, if an officer makes contact with a suspect, the contact must be

“documented as appropriate in the I/Leads Records Management System” or by “using the

COMMENT button from the event screen in I/MOBILE.” The I/Leads system documents arrests

or a contact between an officer and a suspect. There is no connection between the ALPR

program and the I/Leads police report system. The two are separate systems.

The ALPR database does not contain the name or other identifying information about the

owner of the vehicle. To obtain this information, the officer must log off of the ALPR database

and log on to a separate database, such as the VCIN, NCIC, or Department of Motor Vehicles

(“DMV”) databases, that are maintained by other agencies. There is no computerized link

between the ALPR database and these other databases.

Beyond “active use,” the Police Department also engages in what the parties refer to as

“passive use.” The Police Department maintains a database that stores the images that are

captured, as well as the GPS coordinates of the locations where those images were captured.

This data is stored for 364 days, after which time the information is purged. The database can be

searched only by license plate number. Only police officers who are trained and certified as

ALPR system users can query the database. The Police Department’s passive use of the ALPR

system data is what is at issue in this case.

3 II. INITIAL PROCEEDINGS.

Harrison Neal filed a complaint seeking “an injunction and/or writ of mandamus”

pursuant to the Data Act. He asked the circuit court to prohibit the Police Department from

continuing to collect and store license plate data without suspicion of any criminal activity, i.e.,

the Police Department’s passive use of the technology. Neal contended that the ALPR database

is an “information system” that gathers personal information during its passive use and that this

practice contravenes the Data Act. Neal filed his complaint after he submitted a Freedom of

Information Act request to the Police Department asking for its ALPR records regarding his

vehicle. He received two sheets of paper in response. Each sheet contained a picture of his

vehicle and his license plate, and listed the time and date the photo was taken.

The circuit court entered summary judgment in favor of the Police Department,

concluding the data at issue did not qualify as “personal information” under the Data Act. We

reversed that judgment of the circuit court in Neal v. Fairfax County Police Department, 295 Va.

334 (2018) (“Neal I”). We examined to what extent the data gathered by the ALPR system

constituted “personal information” as defined in the Data Act. Neal I, 295 Va. at. 345-47.

“Personal information” means all information that (i) describes, locates or indexes anything about an individual including, but not limited to, his social security number, driver’s license number, agency-issued identification number, student identification number, real or personal property holdings derived from tax returns, and his education, financial transactions, medical history, ancestry, religion, political ideology, criminal or employment record, or (ii) affords a basis for inferring personal characteristics, such as finger and voice prints, photographs, or things done by or to such individual; and the record of his presence, registration, or membership in an organization or activity, or admission to an institution. “Personal information” shall not include routine information maintained for the purpose of internal office administration whose use could not be such as to affect adversely

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