Doe v. Engel et al

Published by Crandall Consulting · Informational litigation intelligence · Last substantive update: October 12, 2026

Docket / citation: 3:25-cv-02429-JES-VET

Summary

The complaint alleges UCSD Health employees embedded tracking tools that transmitted identifiable medical-search communications. The court dismissed only the federal procurement theory while allowing direct-interception and California privacy claims to proceed. ([law.justia.com](https://law.justia.com/cases/federal/district-courts/california/casdce/3%3A2025cv02429/828404/22/))

Litigation Status

Status, direction, and weight describe how tracked public sources characterize this matter as of our last review — they are informational classifications, not legal assessments.

Procedural Posture

Partial grant and denial of defendants' motion to dismiss or stay a putative nationwide class action. ([cases.justia.com](https://cases.justia.com/federal/district-courts/california/casdce/3%3A2025cv02429/828404/22/0.pdf?ts=1790772308))

Reported Holding

Medical-search allegations supported standing and surviving privacy claims; procurement alone did not support the federal civil claim. ([cases.justia.com](https://cases.justia.com/federal/district-courts/california/casdce/3%3A2025cv02429/828404/22/0.pdf?ts=1790772308))

What the Court Decided

Denied abstention as moot, rejected standing dismissal, deferred discretionary immunity, dismissed the procurement theory, and otherwise allowed both counts to proceed. Defendants must answer within 21 days. ([cases.justia.com](https://cases.justia.com/federal/district-courts/california/casdce/3%3A2025cv02429/828404/22/0.pdf?ts=1790772308))

What the Court Did Not Decide

Actual interception and individual policy discretion remained unresolved; the court did not weigh abstention factors. ([cases.justia.com](https://cases.justia.com/federal/district-courts/california/casdce/3%3A2025cv02429/828404/22/0.pdf?ts=1790772308))

Significance

Generally viewed as plaintiff-favorable. Characterizations of significance describe how the matter has generally been discussed in tracked public sources; individual holdings are often narrow, procedural, or fact-specific, and this page does not state or imply broader holdings than the sources support.

What This Page Does and Does Not Say

This page reports what our tracked public sources say about this matter — including, where identified, the procedural posture (for example, a ruling on a motion to dismiss is not a final merits decision). It does not report legal conclusions beyond those sources, does not predict outcomes, and does not constitute legal advice.

Technologies at Issue

• Meta Pixel
• Google Analytics
• Fullstory Session Replay

Third parties named or identified in tracked sources: Meta Platforms, Inc., Google LLC, Fullstory, Inc..

Statutes Invoked

• Federal Wiretap Act, as amended by ECPA, 18 U.S.C. § 2510 et seq.; California Constitution, Article I, Section 1; California Government Code § 820.2 — one-party consent · private right of action
• Federal Wiretap Act/ECPA, 18 U.S.C. § 2510 et seq.; California Constitution, Article I, Section 1; California Government Code § 820.2 — one-party consent · private right of action

Claims Asserted

Claims identified in tracked public sources; pleadings may include additional or amended claims.

• Federal Wiretap Act / ECPA interception claim
• California constitutional invasion of privacy
• Federal Wiretap Act/ECPA interception

What This Matter May Mean for Website Operators

Federal Wiretap Act (ECPA Title I) is a one-party consent statute with a private right of action. Consent standard and private enforceability are the structural features that most shape where website tracking claims are filed and how they are valued.

For operators using similar technologies, the recurring factual questions in matters like this one are when session recording begins relative to consent and whether input masking covers every field; whether advertising pixels transmit page URLs or hashed form data before a consent choice; what page URLs and query strings analytics tools share with third parties. Our scanner tests these behaviors empirically.

Because this matter is pending, anything reported here is procedural — allegations and interim rulings, not final determinations.

Detection of a similar technology on a website is an informational risk indicator, not a legal conclusion, and nothing in this section is legal advice.

Related Intelligence

Sources

• Doe v. Engel et al, 3:2025cv02429 — Document 22 (S.D. Cal. 2026) — U.S. District Court for the Southern District of California, via Justia · Tier A (Primary authority) · 2026-09-29
• Doe v. Engel et al — Document 22: Order Granting in Part and Denying in Part Motion to Dismiss — U.S. District Court for the Southern District of California (via Justia) · Tier A (Primary authority) · 2026-09-29

About This Page

Publisher: Inspection-Ready Institute, Inc. (DBA Crandall Consulting), an independent website compliance and risk consultancy. We are not a law firm and nothing on this page is legal advice.

How this content is produced: Facts are extracted from publicly available sources — court and government materials, recognized legal press, professional analysis, and industry reports — by our litigation intelligence engine, stored with full source provenance, and rendered from the database. Risk guidelines are computed by a deterministic formula, never by an AI model directly. See the full methodology.

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