The public has always been obsessed with the lives of celebrities, and the digital era, with the proliferation of news sources and ability to distribute video instantly across the world, has only increased this fascination. Because the First Amendment protects reporting on matters of public concern, the status of celebrities as public figures often limits their right to privacy, giving them little recourse against even the most invasive news gathering and reporting. Courts have been reluctant to draw the difficult line between material protected by rights of privacy and matters of public concern. When a celebrity’s image or private information is used in connection with reporting the news, courts often defer to the media, simply assuming that the story would not be reported if it was not of interest. But as advances in technology allow us to get even closer, with long-range camera lenses able to capture the most private moments, often without the subjects’ knowledge, that easy assumption may have much less justification.
A Florida federal district court recently addressed celebrity privacy issues in Bollea v. Gawker Media LLC, 2012 WL 5509624 (M.D. Fla. November 14, 2012). Terry Bollea, professionally known as Hulk Hogan, sued Gawker, a celebrity gossip website, for publishing excerpts of a sex tape recorded six years before, when he was still married, featuring Bollea and a woman who was not his wife. Bollea claimed he was unaware the encounter was being filmed. He sought a preliminary injunction against Gawker, claiming violations of various privacy laws and intentional and negligent infliction of emotional distress.
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