Creel v. I.C.E. & Associates, Inc.
Indiana Court of Appeals
771 N.E.2d 1276 (2002)
- Written by Sarah Hoffman, JD
Facts
Myra Creel (plaintiff) was injured in a motor-vehicle collision. She applied for long-term disability through an insurance policy provided by her employer. The insurance denied her claim, and she appealed. The insurance employed a licensed private detective agency, I.C.E. & Associates, Inc. (I.C.E.) (defendant) to confirm Myra’s physical condition and employment status by surveying her. The investigator followed Myra to church, where her husband, Claude Creel, was pastor. The investigator attended and recorded church services with a hidden video camera. The services were open to the public, and the investigator recorded only public services and public areas of the church. The recordings captured Myra playing piano on stage during the services. The insurance denied Myra’s appeal based on the video recordings. Myra and Claude about learned the recording and subsequently filed suit against I.C.E. for invasion of privacy and infliction of emotional distress. The trial court granted summary judgment in I.C.E.’s favor.
Rule of Law
Issue
Holding and Reasoning (Baker, J.)
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