Mezzacappa, T. v. Northampton Co., Aplt.

Summary

The Supreme Court held that a mug shot is an “identifiable description” within the definition of criminal history record information under CHRIA and that, under Section 9121(b), only a police department may disseminate such information to individuals, thus the County, as a non‑law‑enforcement agency, may not release the mug shots. The Court reversed the Commonwealth Court and declined to remand for a privacy‑balancing test.