During debate over his nomination, Bork's video rental history was leaked to the press. His video rental history was unremarkable, and included such harmless titles as "A Day at the Races", "Ruthless People", and "The Man Who Knew Too Much". Writer Michael Dolan, who obtained a copy of the hand-written list of rentals wrote about it for the "Washington City Paper". Dolan justified accessing the list on the ground that Bork himself had stated that Americans had only such privacy rights as afforded them by direct legislation. The incident led to the enactment of the 1988 Video Privacy Protection Act.