T]he elements of the public-disclosure-of-private-facts tort are as follows:
- public disclosure;
- of a private fact;
- which would be offensive and objectionable to the reasonable person; and
- which is not of legitimate public concern.
The element of public disclosure “must be accompanied by publicity in the sense of communication to the public in general or to a large number of persons as distinguished from one individual or a few.” Kinsey v. Macur, 107 Cal. App. 3d 265, 271 (1980).
CALIFORNIA STATE COURTS
Supreme Court of California: Shulman v. Group W Productions, 18 Cal. 4th 200, 214 (1998).
California 1st District: Moreno v. Hanford Sentinel, Inc., 172 Cal. App. 4th 1125, 1129-30 (2009).
California 2d District: Morrow v. Los Angeles Unified School Dist., 149 Cal. App. 4th 1424, 1440 (2007).
California 3d District: Matson v. Dvorak, 40 Cal. App. 4th 539, 550 (1995).
California 4thDistrict: Ignat v. Yum! Brands, Inc., 214 Cal. App. 4th 808, 820-21 (2013).
California 5th District: Moreno v. Hanford Sentinel, Inc., 172 Cal. App. 4th 1125, 1129-30 (2009).
California 6th District: None.
CALIFORNIA FEDERAL COURTS
United States Court of Appeal for the 9th Circuit: Doe v. Gangland Prods., No. 11-56325, 2013 U.S. App. LEXIS 19102, at *26 (9th Cir. Sept. 16, 2013).
Central District: Carafano v. Metrosplash, Inc., 207 F. Supp. 2d 1055, 1068 (C.D. Cal. 2002), aff’d, 339 F.3d 1119 (9th Cir. 2003).
Eastern District: Grant v. United States, No. 2:11-cv-00360 LKK KJN PS, 2011 U.S. Dist. LEXIS 61833, at *15 (E.D. Cal. June 9, 2011).
Northern District: Doe v. John F Kennedy Univ., No. C-13-01137 DMR, 2013 U.S. Dist. LEXIS 122050, at *34-35 (N.D. Cal. Aug. 27, 2013).
Southern District: Tourgeman v. Collins Fin. Servs., No. 08-CV-1392 JLS (NLS), 2011 U.S. Dist. LEXIS 81070, at *33 (S.D. Cal. July 26, 2011).