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Bullard v. MRA Holding, LLC

Supreme Court of Georgia
740 S.E.2d 622 (2013)


Two men filmed Lindsey Bullard (plaintiff), a 14-year-old girl from Georgia, as she exposed her breasts while on spring break in Florida. Bullard was aware that the men were videotaping her and did not object. MRA Holding, LLC (MRA) (defendant), a company that distributed pornographic movies, subsequently obtained the video clip and used it in one of its Girls Gone Wild videos. Additionally, MRA used a still photo of Bullard taken from the video clip and placed it on the video box’s cover. Bullard’s exposed breasts were blocked out with the words “Get Educated!” in the block. MRA marketed and sold the video nationwide, including in Georgia. Further, television and internet advertisements were aired that used Bullard’s image. Bullard filed suit against MRA in federal district court in Georgia for appropriation of her likeness without her consent. MRA moved for summary judgment. The district court certified a question to the Supreme Court of Georgia on the topic of whether Georgia or Florida law governed Bullard’s claim.

Rule of Law


Holding and Reasoning (Melton, J.)

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