The U.S. Supreme Court case Buck Doe v. Elaine L. Chao, Secretary of Labor in 2003 revolved around the issue of whether a federal employee could sue for damages under the Privacy Act due to emotional distress caused by an agency's intentional or willful failure to maintain accurate records resulting in adverse determinations made about him/her. The plaintiff, Buck Doe, alleged that his employer (the Department of Labor) had intentionally and willfully failed to keep accurate employment records which led to negative decisions regarding his employment status causing him significant emotional distress and harm. However, the court ruled against Doe stating that he was not entitled to "actual damages" because he did not provide evidence of tangible economic loss as required by the Privacy Act.

In the dissenting opinion for Buck Doe v. Elaine L. Chao, Secretary of Labor, 2003, it was argued that the majority's decision to uphold a Department of Labor regulation requiring employers to pay overtime wages only after an employee has worked more than 40 hours in a week is inconsistent with the Fair Labor Standards Act (FLSA). The FLSA mandates that employees should receive overtime compensation when they work over eight hours per day and not just beyond forty hours in a week. The dissenting justices believed this interpretation would better align with Congress' intent when passing the law - protecting workers from long working days rather than merely limiting their total weekly hours. They also expressed concerns about potential employer abuses under this ruling as businesses could potentially exploit employees by making them work excessively long shifts without additional compensation so long as they do not exceed forty total weekly working hours.