Brief Fact Summary.
Haynes was negatively featured in a book following his ex-wife’s life. Haynes admitted to many of the incidents described in the book but argued that he had since turned his life around in the past 25 years.
Synopsis of Rule of Law.
An involuntary loss of privacy is not a proper cause of action under the privacy tort unless the private facts published would make a reasonable person deeply offended by such publicity (offensiveness) and the facts must be those in which the public has no legitimate interest (newsworthiness).
Substitute the true for the false (if Haynes is believed), and the damage to Haynes's reputation would be no less.View Full Point of Law
A book on the social, political, and economic effects of the movement of Black people from the rural South to cities in the North between 1940 and 1970 followed the life and experiences of Daniels. In the book, Daniels discussed her relationship with her ex-husband, Haynes, and made statements alleging that Haynes was a drunk, neglected his children, could not keep a job, was unfaithful, and eventually left her for another woman.
Haynes admitted to many of the incidents described in the book but argued that he had since turned his life around in the past 25 years. He sued the author and publisher for libel and invasion of privacy.
Did the publication of negative personal facts on Haynes’ life as the ex-husband of Daniels constitute an invasion of privacy?
No. The publication of negative personal facts on Haynes’ life as the ex-husband of Daniels did not constitute an invasion of privacy.
Invasion of privacy covers, in relevant part, publicizing personal facts that while true and not misleading are so intimate that their disclosure to the public is deeply embarrassing to the person thus exposed and is perceived as gratuitous by the community. This is because even people who have nothing to be ashamed about in their lives would be mortified at intimate details of their lives being published.
Here, no sexual act is described in the book, nor are any intimate details revealed. Instead, what is described is misconduct on the part of Haynes.
In Melvin, the court found a properly stated claim for invasion of privacy for a plaintiff who was a former prostitute acquitted of murder whose scandalous past was revealed seven years after she had distanced herself from that past in a movie that used her maiden name. Here, Haynes had been married to his new wife for over thirty years with a respectable income and position as a deacon at his local church.
In Sidis, the court found no claim for invasion of privacy for a child prodigy who had fizzled out into a recluse because no intimate physical details of Sidis’ life were revealed, indicating a shift for in modern thinking for the proper balance between the right of privacy and the freedom of the press.
A person has no legal right to keep private details of their lives that are newsworthy, even if that person would prefer to keep those experiences private.
An individual will be most offended by the publication of intimate details of her life if the community has no interest in them beyond voyeuristic thrill. Here, the reader has a legitimate interest in the aspects of Luther’s conduct that the book does reveal, which includes intersections of morality with governmental programs to alleviate poverty. Reporting true facts about real people is necessary to obviate any impression that the problems raised in the book are remote or hypothetical.