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Gates v. Discovery Communications, Inc.

Supreme Court of California
101 P.3d 552 (2004)


Facts

Steve Gates was convicted of being an accessory after the fact to a murder for hire, and served a three-year prison sentence, after which he lived an obscure and lawful life. More than a dozen years after the crime occurred, Discovery Communications, Inc. and another company (together, Discovery) aired a documentary that presented an account of the crime based on information gathered from public, official court records. Gates (plaintiff) sued Discovery (defendants), alleging defamation and an invasion of privacy. The trial court dismissed the defamation claim because the disclosures were accurate, but denied Discovery’s request to dismiss the invasion of privacy claim. The Court of Appeal reversed as to the invasion of privacy claim, holding that Discovery’s disclosures were truthful and were contained in the public records of a judicial proceeding, and were accordingly protected under the First Amendment. The Supreme Court of California granted review.

Rule of Law

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Issue

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Holding and Reasoning (Werdegar, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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