Nader v. General Motors Corp.

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Nader v. General Motors Corp.
Case Title Nader v. General Motors Corp. (25 N.Y. 2d 560, 1970)
Date
Appealed No
Personal Information
Taxonomy
Link to Ruling
Country/Jurisdiction United States
State or Province New York
Regulatory Bodies
Decided Yes
Arbitrator US Supreme Court
Related Laws

Short Summary

Nader v. General Motors Corp. (25 N.Y. 2d 560, 1970) was a court case in which author and automobile safety lecturer Ralph Nader claimed that General Motors had "conducted a campaign of intimidation against him in order to 'suppress plaintiff's criticism of and prevent his disclosure of information' about its products" regarding his book Unsafe at Any Speed. Mere information gathering is not sufficient for action under intrusion upon seclusion tort: "privacy is invaded only if the information sought is of a confidential nature and the defendant's conduct was unreasonably intrusive." Judge Brietel concluded that GM's actions "constitute intrusion upon privacy". Among the court's findings was the conclusion that private detectives hired by General Motors to follow Nader were in their rights to follow him into a bank, but they crossed a line when looking over his shoulder to read what he was writing on a deposit slip.

Background

The issue was whether respondent was able to sufficiently set out his claim of invasion of privacy. Appellants sought review of appellate court's order denying appellants' motion to dismiss in respondent's action for invasion of privacy. Respondent alleged appellants engaged in harassing conduct with intent of preventing respondent from publishing his book, which criticized appellants' safety and design of automobiles. Court affirmed and determined that under law of District of Columbia, respondent had set out a claim for invasion of privacy. Court found District of Columbia intended to protect individuals from others who would unreasonably intrude into the personal affairs of others and disclose confidential information about the individual. There was no invasion of privacy claim set out where respondent alleged appellants asked friends of respondent personal information about respondent. The first two causes of action do contain allegations which are adequate to state a cause of action for invasion of privacy under District of Columbia law, the courts below properly denied the appellant's motion to dismiss those causes of action. It is settled that, so long as a pleading sets forth allegations which suffice to spell out a claim for relief, it is not subject to dismissal by reason of the inclusion therein of additional nonactionable allegations. Thus, Court affirmed appellate court's decision, finding under District of Columbia law respondent sufficiently set out invasion of privacy claim where respondent alleged an unreasonable intrusion by appellants into confidential matters of respondent.

Decision

The mere gathering of information about a particular individual does not give rise to a cause of action for invasion of privacy. Privacy is invaded only if the information sought is of a confidential nature and the defendant's conduct was unreasonably intrusive. Just as a common-law copyright is lost when material is published, so, too, there can be no invasion of privacy where the information sought is open to public view or has been voluntarily revealed to others.