Godbehere v. Phoenix Newspapers, Inc.

Brief Fact Summary.

The Arizona Supreme Court ruled that a public official cannot be successful in a claim for false light invasion of privacy if the publication in question relates to the public official’s public duties.

Synopsis of Rule of Law.

If a publication regarding a public official regards the official’s public duties or his performance of those duties then the public official will not be able to bring a suit for false light invasion of privacy.

Facts.

During the spring and summer of 1985, the Phoenix Newspapers, Inc. (Defendant) published over 50 articles pertaining to Sherriff Richard Godbehere and other deputies alleging they participated in illegal activities including illegal arrests, misuse of funds, and police brutality. Plaintiff filed suit for false light invasion of privacy. The defendant’s motion for dismiss was granted and plaintiff appeals. 

Issue.

Whether a public official can bring a claim for false light invasion of privacy when the articles that were published pertained to his duties and performance of those duties in his official capacity. 

Held.

No. The Court rules that since the public as a specific interest in the matter regarding how officers perform their duties, the publisher cannot be held liable for false light invasion of privacy since these accusations regard the official’s job. 

Discussion.

The Court iterates that the Sherriff could have been successful if he could have proven that the articles that were published regarded his personal life and not his life as a public official.