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Bodah v. Lakeville Motor Express
Minnesota Supreme Court
663 N.W.2d 550 (2003)
Lakeville Motor Express, Inc. (LME) (defendant) faxed employee lists to 16 separate managers in multiple states, asking the managers to confirm who actually worked at those locations. These lists contained the names and Social Security numbers of 204 individuals (plaintiffs). The individuals on the lists sued LME for invasion of their privacy, alleging that LME had committed the tort of public disclosure of private facts by publishing the individuals’ Social Security numbers to the 16 managers. The parties agreed about the basic facts but disagreed about what type of publication or publicity was required to state a claim for public disclosure of private facts. The trial court found that LME’s disclosure was not public enough to support a public-disclosure claim and dismissed the case. The court of appeals found that publicity meant any disclosure that unreasonably exposed someone to a significant risk of loss and that LME’s disclosure had potentially exposed the individuals to loss. Thus, the court of appeals reversed the trial court and reinstated the public-disclosure claim. LME appealed to the Minnesota Supreme Court.
Rule of Law
Holding and Reasoning (Anderson, J.)
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