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Shulman v. Group W Productions, Inc.

Supreme Court of California
18 Cal. 4th 200, 955 P.2d 469, 74 Cal. Rptr. 2d 843 (1998)

Written by Craig Conway, LLM

Facts

Ruth Shulman and another family member (plaintiffs) were injured when their car went off the highway, overturned, and trapped them inside. A medical transport and helicopter provided assistance to Shulman and the passenger. Accompanying the paramedics was a video camera operator employed by a television producer who worked for Group W Productions, Inc. (Group W) (defendant). The cameraman filmed Shulman’s extrication from the vehicle, the medical care provided, and her transportation to a hospital in the helicopter. At the same time, a small microphone placed on a nurse captured audio conversations with Shulman and her family member. The video and audio were edited and subsequently broadcast on a television documentary show. Neither Shulman nor her family member consented to the video or audio taping of the rescue efforts or of the broadcast. Shulman brought suit against Group W for invasion of privacy, more specifically intrusion into private places, conversations or other matters. The trial court granted Group W’s motion for summary judgment, and Shulman appealed. The court of appeal revered, holding that there were genuine issues of material fact as to Shulman’s claims. Group W appealed to the California Supreme Court.

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Holding and Reasoning (Werdegar, J.)

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Dissent (Chin, J.)

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