Uhl v. Columbia Broadcasting Systems, Inc.

476 F. Supp. 1134 (1979)

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Uhl v. Columbia Broadcasting Systems, Inc.

United States District Court for the Western District of Pennsylvania
476 F. Supp. 1134 (1979)

SH

Facts

Columbia Broadcasting Systems, Inc. (CBS) (defendant) ran a TV special about bad hunting practices. It featured a series of framed shots of Clare Randall Uhl (plaintiff) and several other hunters. The shots showed first wild geese on the ground, then the hunters hiding in a blind, and then Uhl picking up the geese after they had been shot. It made it appear that the hunters had shot the geese while the geese were on the ground. In truth, the hunters had shot the geese while they were in the air, even though CBS’s photographers had urged them to shoot the geese on the ground. Uhl filed suit against CBS for false-light invasion of privacy. At trial, Uhl offered testimony from several people that it was considered unsportsmanlike to shoot geese while they stood on the ground and that it was considered a serious insult to accuse a hunter of doing so. The jury found in favor of Uhl on the grounds that a reasonable person would find the false portrayal offensive and awarded Uhl nominal damages. CBS appealed, arguing that the statement was protected by CBS’s First Amendment privilege under the public-interest exception.

Rule of Law

Issue

Holding and Reasoning (Weber, J.)

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