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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Segura v. Cabrera, 184 Wash. 2d 587 (2015)

Citation
Segura v. Cabrera, 184 Wash. 2d 587 (2015)
Parent Document
Segura v. Cabrera, 184 Wash. 2d 587 (2015)
Jurisdiction
Washington (state)
Effective Date
2015-10-29

Other Sections in This Document (60)

Full Text

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¶19 Similarly, as the Supreme Court recently observed, “actual damages” has a “chameleon-like quality” because “the precise meaning of the term ‘changes with the specific statute in which it is found.’ ” Fed. Aviation Admin, v. *596Cooper, 566 U.S. 284, 294, 292, 132 S. Ct. 1441, 182 L. Ed. 2d 497 (2012) (holding “actual damages” does not include emotional distress damages as used in the Privacy Act of 1974, codified in part at 5 U.S.C. § 552a (quoting Cooper v. Fed. Aviation Admin., 622 F.3d 1016 (9th Cir. 2010))). As the Court noted, sometimes the term includes emotional distress damages, while in other contexts it includes only pecuniary harm. Id. at 1449.