Haynes v. Alfred A. Knopf, Inc

Brief Fact Summary. Defendants published a book of social and political history that mentioned embarrassing experiences of Plaintiffs. Plaintiffs sued Defendant for invasion of privacy.

Synopsis of Rule of Law. In order to maintain an action for invasion of privacy: (1) the private facts publicized must make a reasonable person deeply offended; and (2) the public has no legitimate interest in the facts.

Facts. Defendants are Nicholas Lemann, the author of a highly praised, best-selling book of social and political history called The Promised Land: The Great Black Migration and How It Changed America (1991), and Alfred A. Knopf, Inc., the book’s publisher. Luther Haynes and his wife (Plaintiffs) claim the book libels Luther Haynes and invades both Plaintiff’s right of privacy. Ruby Lee Daniels’ story is the spine of the book. The book details her migration and marriage to Plaintiff Luther Haynes. The book states that the marriage ended in divorce and Plaintiff Luther Haynes married another woman. The revelations in the book about Plaintiff Luther Haynes are not about the intimate details of Plaintiffs. The revelations are about Plaintiff Luther Haynes’ heavy drinking, unstable employment, adultery, and irresponsible behavior. Defendants were granted summary judgment. Plaintiffs appealed.

Issue. Have Plaintiffs’ privacy rights been invaded if a Plaintiff Luther Haynes is depicted negatively in Defendants’ book that evaluates social and political questions?

Held. No. Judgment affirmed.
* The Court affirmed the dismissal of the defamation portions of the complaint on the ground that any deviations from the truth were too insubstantial to support an action for libel.
* The First Amendment greatly circumscribes the right even of a private figure to obtain damages for the publication of newsworthy facts about him, even when they are facts of a kind that people want very much to conceal. People who do not the limelight and do not deliberately choose a way of life or course of conduct calculated to thrust them into it nevertheless have no legal right to extinguish it if the experiences that have befallen them are newsworthy, even if they would prefer that those experience be kept private. The possibility of an involuntary loss of privacy is recognized in the modern formulations of this branch of the privacy tort, which require not only that the private facts publicized by such as would make a reasonable person deeply offended by such publicity but also that they be facts in which the public has no legitimate interest.
* Distinguished scholars, among them black scholars covering a large portion of the ideological spectrum, have praised Defendants’ book to the skies. Defendants’ mythology places the individual case history at center stage. If Defendants cannot tell the story of Ruby Daniels without waivers from every person who they think did her wrong, they cannot write the book.

Discussion. In order for Defendant’s book to be the success that it is, it was necessary for Defendant to tell the personal story of books main character, Ruby Lee Daniels. Requiring Defendants to omit persons, facts and events from a social and historical book would make the book near impossible to write.