Medical Laboratory Management Consultants v. American Broadcasting Companies, Inc.
United States Court of Appeals for the Ninth Circuit
306 F.3d 806 (2002)
- Written by Sara Adams, JD
Facts
John Deveraj (plaintiff) owned Medical Laboratory Management Consultants (Medical Lab) (plaintiff), an Arizona laboratory that tested Pap smear samples. Deveraj and Medical Lab were featured on an investigative segment produced by several employees of American Broadcasting Companies, Inc. (ABC) (defendants). ABC producer Robbie Gordon set up a meeting with Deveraj by feigning an interest in opening her own laboratory. Gordon was accompanied to the meeting by cameraman Jeff Cooke, who wore a wig with a hidden camera. This was the first time any of the ABC employees met Deveraj in person. Deveraj only discussed business matters with the ABC employees, never requested that the information be kept private, and provided a tour of the facility that was commonly given to other visitors. During the tour, the only place Deveraj stopped anyone from entering was his personal office. Deveraj sued ABC in federal court for several claims, including intrusion on seclusion. Deveraj argued he had an expectation of privacy in Medical Lab’s offices, in the content of his conversations with the ABC employees, and in his conversations not being secretly recorded. ABC filed a motion for summary judgment. The district court granted the motion, and Deveraj appealed.
Rule of Law
Issue
Holding and Reasoning (Hug, J.)
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