Does the Privacy Act's "actual damages" provision cover mental and emotional distress?

In 2006, pilot Stanmore Cooper disclosed that he was HIV-positive to Social Security officials in order to receive medical benefits but withheld his status from the Federal Aviation Administration. But the Social Security Administration then turned over his medical records to the FAA, which revoked his license. Cooper filed suit against the agency for emotional distress for mishandling his medical records. The U.S. Court of Appeals for the Ninth Circuit ruled that the exchange of records was improper and that Cooper has standing to sue. This place was argued before the U.S Supreme Court last year. The Supreme Court ruled that the authorization of suits against the government for “actual damages” in the Privacy Act of 1974 is not sufficiently clear to constitute a waiver of sovereign immunity from suits for mental and emotional distress. I'm not very familiar with the Privacy act, however it is only logical to ask for a person's authorization before to disclose medical records, specially to your employer.