55 N.Y.2d 433 (1982)
In New York, a cause of action for invasion of privacy is strictly limited to the statutory provisions outlined in Sections 50 and 51 of the Civil Rights Law, precluding common-law claims for invasion of privacy based on unreasonable publicity.
Summary
Plaintiffs sued over portrayals in books and a movie, claiming invasion of privacy and defamation. The New York Court of Appeals affirmed the dismissal of the invasion of privacy claim, holding that New York does not recognize a common-law right to privacy beyond the statutory protections in Sections 50 and 51 of the Civil Rights Law, which prohibit the use of a person’s name, portrait, or picture for commercial purposes without consent. Since the plaintiffs’ names, portraits, or pictures were not used, no cause of action existed under the statute. The defamation claims were not addressed in this motion to dismiss and remained for later consideration.
Facts
The plaintiffs alleged that the defendants, for commercial gain, portrayed them with detailed accuracy in books and a movie represented as true stories. They asserted that the portrayals were so accurate regarding their physical characteristics and activities that they were effectively identified, leading to an invasion of their privacy.
Procedural History
The plaintiffs brought suit alleging invasion of privacy and defamation. The defendant moved to dismiss. The lower court denied the motion regarding the invasion of privacy claim, but the appellate division reversed. The New York Court of Appeals granted leave to appeal and affirmed the appellate division’s order dismissing the invasion of privacy claim, while the defamation claims were not part of this appeal and remained for future proceedings.
Issue(s)
Whether New York State recognizes a common-law right to judicial relief for invasion of privacy based on unreasonable publicity, beyond the protections afforded by Sections 50 and 51 of the Civil Rights Law.
Holding
No, because in New York, the right to judicial relief for invasion of privacy is limited to the statutory provisions outlined in Sections 50 and 51 of the Civil Rights Law, and does not extend to common-law claims based on unreasonable publicity.
Court’s Reasoning
The Court of Appeals reasoned that the plaintiffs’ claim for invasion of privacy failed because Sections 50 and 51 of the Civil Rights Law exclusively govern such claims in New York. These sections prohibit using a person’s “name, portrait or picture” for commercial purposes without consent. Since the defendants did not use the plaintiffs’ names, portraits, or pictures in the books or movie, there was no violation of the statute. The court explicitly stated, “whatever may be the law in other jurisdictions with respect to the right to judicial relief for invasion of privacy in consequence of unreasonable publicity, in our State thus far there has been no recognition of such right other than under sections 50 and 51 of the Civil Rights Law.” The court reinforced the idea that any expansion of privacy rights in New York must come from the legislature, not the courts. The court distinguished this case from defamation claims, which were not addressed by the motion to dismiss and remained open for future litigation. This underscores the court’s strict interpretation of the statutory limits on privacy claims, leaving potential plaintiffs with limited recourse in situations where their likeness or identity is not directly exploited.