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Taggart v. Wadleigh-Maurice, Ltd. - 489 F.2d 434 (3d Cir. 1973)

Rule:

N.Y. Civ. Rights Law § 51 may not be applied to afford relief either to a public figure or in a matter of public interest in the absence of proof that the defendant published false material with knowledge of its falsity or in reckless disregard of the truth. 

Facts:

Appellant Thomas Taggart was working to empty portable latrines during the Woodstock concert and was filmed performing his duties by appellee photographers Wadleigh-Maurice, Ltd. who placed the footage in a documentary which was distributed for profit by appellee film distributor. Appellant argued that the filming for commercial purposes invaded his right to privacy and detrimentally affected his social and family life. Appellant sought damages and an injunction to stop distribution of the film with the offending scene. The district court found that appellant was a participant in a newsworthy event and that the state's privacy statute, N.Y. Civ. Rights Law § 51, was not applicable. 

Issue:

Did the district court err in holding that appellant was a participant in a newsworthy event and that the state's privacy statute, N.Y. Civ. Rights Law § 51, was not applicable?

Answer:

Yes.

Conclusion:

The court reversed the district court's judgment. The court found that the district court made its decision only based on appellees' evidence which supported their position before appellant had an opportunity to present his entire case. The court noted that the record clearly showed disputed factual issues and, as such, a jury should have determined the resolution of whether appellant's right to privacy was violated.

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