In March and April 1998, John Doe, an employee of the U.S. Postal Service, missed several weeks of work because of an AIDS-related illness. Doe’s supervisor told him that he had to submit an administrative form and a medical certificate explaining why he has sick or he would face disciplinary action for his unexplained absence. He was informed that he may qualify for coverage under FMLA and his supervisor provided him with the appropriate forms to fill out and return. Doe decided to pursue an FMLA request and his physician completed the forms, indicating that Doe had “AIDS related complex” and “chronic HIV infection.” Doe submitted the request forms to his employer and, upon his return to work, discovered that his HIV status had become common knowledge among co-workers. Several co-workers made comments to him about his condition and many identified his supervisor as the source of the information. Doe filed a suit against the U.S. Postal Service for violation of the Privacy Act, alleging that Postal Service employees disclosed medical information contained in his FMLA forms. Can Doe prove his case? [John Doe v. U.S. Postal Service, No. 01-5395 (DC. Cir. Feb. 7, 2003).]