Andrew H. Speaker, the lawyer who made headlines when he took a trans-Atlantic commercial flight while infected with a rare strain of tuberculosis, probably lost his bid to hold the Centers for Disease Control and Prevention liable for federal privacy act violations because of relatively new case law that changed the standard for dismissal on the eve of Speaker’s filing.

That standard, which limits notice pleadings by requiring them to contain specific factual allegations, was one Speaker failed to meet, according to an opinion and order handed down Nov. 23 by Judge William S. Duffey Jr. of the U.S. District Court for the Northern District of Georgia.