Camfield v. City of Oklahoma City

In 1979, the German film The Tin Drum (film) was released to critical acclaim. Based on a novel, the film followed a character who remained in the body of a young boy while those around the boy aged normally. The film’s story took place during the rise of Nazism in the 1930s and 1940s. At the end of World War II, the character of the boy chose to continue growing. In 1997, the Oklahoma City Police Department (department) (defendant) received a tip that the film (which at that time had been around for 20 years) contained child pornography. A police officer watched the film, decided that it did contain child pornography, and sought judicial confirmation of this opinion from a state-court judge. The judge agreed. The judge found that three scenes portrayed a then-11-year-old actor engaged in sexual relations with a then-24-year-old actor and that the scenes contained child pornography. Officers went to video rental stores across Oklahoma City to collect copies of the film; if the film was rented out, the officers would gather the information of the renter and go to the individual’s home to retrieve the copy. One of the renters, Michael Camfield (plaintiff), was an attorney for the American Civil Liberties Union. Camfield had learned of the controversy and was watching the film to formulate legal arguments. The officers told Camfield that the film contained child pornography. Camfield disagreed. Eventually, Camfield turned over the film copy. Camfield then sued the department, alleging (among other things) violations of the Video Privacy Protection Act (VPPA). The district court concluded that the officers had violated the VPPA as a matter of law. However, the amount of damages incurred was a factual question, the court held, so that matter went to trial. A jury awarded Camfield the statutory minimum of $2,500 in liquidated damages for the VPPA claim.