BILL ANALYSIS                                                                                                                                                                                                    



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          Date of Hearing:  May 12, 2009

                           ASSEMBLY COMMITTEE ON JUDICIARY
                                  Mike Feuer, Chair
                     AB 524 (Bass) - As Amended:  April 29, 2009
           
          SUBJECT  :  Invasion of privacy

           KEY ISSUE  :  Should a person who has actual knowledge that an  
          image or recording was obtained in violation of the state's  
          "invasion of privacy" statute, also be considered to be in  
          violation of that statute? 

           FISCAL EFFECT  :  As currently in print this bill is keyed  
          non-fiscal. 

                                      SYNOPSIS
                                          
          This important privacy protection measure seeks to strengthen  
          existing legal law designed to thwart privacy invasions that can  
          cause great harm to many Californians.  In response to the 1998  
          death of Princess Diana, and other reports of overzealous  
          paparazzi endangering celebrities and those around them, the  
          Legislature created a statutory cause of action for "invasion of  
          privacy" to supplement the common law tort of invasion of  
          privacy, and the tort of "intrusion" in particular.  The  
          statutory cause of action for "physical invasion of privacy"  
          covers the knowing entry onto the land of another, or invasion  
          of another place where a person has a reasonable expectation of  
          privacy, in order to capture an image or recording of that  
          person engaged in a "personal or familial" activity.  In  
          addition, the statute creates a cause of action for  
          "constructive invasion of property" where the image or recording  
          is captured from a distance by means of technologically enhanced  
          equipment, where the image or recording could not otherwise have  
          been captured without trespassing on the private space of the  
          subject.  Currently, this statutory action only applies to the  
          person who actually captures the image or recording.  It does  
          not apply to a person or entity - such as a newspaper or  
          Internet Web site - that did not directly participate in the act  
          of capturing the image or recording, but then subsequently  
          publishes or broadcasts the potentially illegally obtained image  
          or recording.  Indeed, existing law expressly states that the  
          subsequent sale, transmission, publication, broadcast, or use of  
          the image or recording "shall not itself constitute a violation"  







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          of the statute, even though a plaintiff can still bring an  
          action against the publisher on common law theories, such as  
          public disclosure of a private fact or "false light."  This bill  
          seeks to broaden the reach of the state's "invasion of privacy"  
          statute to include a person who sells, transmits, or publishes  
          the image if that person has "actual knowledge the images or  
          recordings were obtain illegally."  

           SUMMARY  :  Seeks to provide greater protection to the privacy  
          interests of all Californians by amending existing law so that a  
          person who sells, transmits, publishes, or broadcasts an image,  
          recording, or physical impression of someone engaged in a  
          personal or familial activity violates the state's "invasion of  
          privacy" statute if that person, even though not the one  
          actually capturing the image, recording, or impression, has  
          actual knowledge that the image, recording, or impression was  
          unlawfully obtained.  Specifically,  this bill  :  

          1)Provides that sale, transmission, broadcast, or use of any  
            image or recording that was obtained in violation of  
            California's existing invasion of privacy statute, relating to  
            unreasonable and offensive intrusions into personal and  
            familial matters, constitutes a violation of the statute if  
            the person selling, transmitting, broadcasting, or using the  
            image or recording has actual knowledge the images or  
            recordings were obtained illegally. 

          2)Makes legislative findings and declarations as to the problem  
            of photographers, videographers, and audio recorders  
            harassing, invading the privacy interest, and sometimes even  
            physically endangering individuals and their families in order  
            to capture images and recordings for commercial purposes.   
            Finds and declares further that the right of a free press to  
            report details of an individual's private life must be weighed  
            against the rights of the individual to enjoy liberty and  
            privacy.

           EXISTING LAW  : 

          1)Recognizes, under the common law, four distinct categories of  
            the tort of "invasion of privacy:" (a) intrusion upon a  
            plaintiff's seclusion or solitude; (b) public disclosure of  
            private facts; (c) publicity that places the plaintiff in a  
            "false light," and (d) appropriation of a plaintiff's likeness  
            or image for the defendant's advantage.  (Turnbull v. ABC,  







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            2004 U.S. Dist. LEXIS 24351.)  

          2)Identifies the required elements of a tort of "intrusion" as  
            (a) intrusion into a private place, conversation, or matter;  
            and (b) in a manner highly offensive to a reasonable person.   
            (Id.) 

          3)Makes it a crime to eavesdrop upon or record a confidential  
            communication, intentionally and without the consent of all  
            parties, by means of an electronic amplifying or recording  
            device.  Makes the offense punishable by a fine not exceeding  
            $2,500, or imprisonment in the county jail not exceeding one  
            year.  Further provides that a person who violates this  
            provision may also be liable in a civil action by a person  
            injured by the violation.  (Penal Code Sections 632 and  
            637.2.) 

          4)Makes a person liable for "physical invasion of privacy" for  
            knowingly entering onto the land of another person or  
            otherwise committing a trespass in order to physically invade  
            the privacy of another person with the intent to capture any  
            type of visual image, sound recording, or other physical  
            impression of that person engaging in a personal or familial  
            activity, and the physical invasion occurs in a manner that is  
            offensive to a reasonable person.  (Civil Code Section 1708.8  
            (a).) 

          5)Makes a person liable for "constructive invasion of privacy"  
            for attempting to capture, in a manner highly offensive to a  
            reasonable person, any type of visual image, sound recording,  
            or other physical impression of another person engaging in a  
            personal or familial activity under circumstances in which the  
            plaintiff had a reasonable expectation of privacy, through the  
            use of a visual or auditory enhancing device, regardless of  
            whether there was a physical trespass, if the image or  
            recording could not have been achieved without a trespass  
            unless the visual or auditory enhancing device was used.   
            (Civil Code Section 1708.8 (b).) 

          6)For purposes of the above provisions, defines "personal or  
            familial activity" as including, but not limited to, intimate  
            details of the plaintiff's personal life, interactions with  
            family or significant others, or other aspects of the  
            plaintiff's private affairs or concerns.  (Civil Code Section  
            1708.8 (l).) 







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          7)Specifies that for purposes of the above provisions, the sale,  
            transmission, publication, broadcast, or use of any image or  
            recording shall not itself constitute a violation of the  
            statute, but neither shall anything in the statute be  
            construed to limit any other rights or remedies that a  
            plaintiff may have in law and equity.  (Civil Code Section  
            1708.8 (f).) 

          8)Specifies that an assault committed with the intent to capture  
            any type of visual image, sounding recording, or other  
            physical impression is subject to enhanced statutory penalties  
            and remedies prescribed.  (Civil Code Section 1708.8 (c).)

          9)Provides that a person who violates the statute for a  
            commercial purpose shall, in additional to any other damages  
            or remedies provided, be subject to disgorgement to the  
            plaintiff or any proceeds or other consideration obtained as a  
            result of the violation of this section.  Defines "commercial  
            purpose" to mean any act done with the expectation of sale,  
            financial gain, or other consideration.  (Civil Code Section  
            1708.8 (d) and (k).) 

          10)Provides that a person who directs, solicits, actually  
            induces, or actually causes another person, regardless of  
            whether there is an employer-employee relationship, to commit  
            a violation of the statute, is liable for any general,  
            special, and consequential damages resulting from each  
            violation.  (Civil Code Section 1708.8 (e).) 

          11)Generally exempts from the statute any lawful activities of  
            law enforcement personnel or employees of governmental  
            agencies or other entities, either public or private who, in  
            the course and scope of their employment, and supported by  
            articuable suspicion, attempt to capture any type of visual  
            image, sound recording, or other physical impression as part  
            of an investigation, surveillance, or monitoring of any  
            conduct in order to obtain evidence of suspected unlawful or  
            fraudulent activity or any pattern of practices that affect  
            public health and safety.  (Civil Code Section 1708.8 (g).) 

           COMMENTS :  This important privacy protection bill seeks to deter  
          the most egregious activities of so-called "paparazzi" by  
          cutting off at the source the financial incentives that often  
          presumably drive the worst and sometimes extremely dangerous  







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          behavior.  Existing law creates a statutory cause of action for  
          "invasion of privacy" that imposes liability on any person who  
          (1) intrudes upon the private space of another person (2) in  
          order to capture images or recordings of that person engaging in  
          a personal or familial activity, and (3) in a manner that is  
          offensive to a reasonable person.  However, while existing law  
          makes the actual  capture  , or attempted capture, of the image or  
          recording a violation, the statute currently expressly states  
          that the selling, transmitting, publishing, or broadcasting of  
          the image or recording is not, by itself, a violation - unless  
          the person publishing the image or recording has actually  
          solicited or directed the culprit to violate the statute.  This  
          bill has been introduced by the Speaker to strengthen the  
          privacy rights of all Californians by amending California's  
          existing "invasion of privacy" by making liable any person who  
          sells, publishes, or broadcasts the image or recording, if that  
          person has "actual knowledge the images or recordings were  
          obtained illegally."  In short, existing law potentially imposes  
          liability on a publisher of such potentially illegally-gotten  
          material to the extent that the publisher may have solicited  
          another to violate the law.  However the violation is for the  
          act of solicited or directing, not for the act of publishing  per  
          se  .  Under this bill, whether or not a publisher played any role  
          in soliciting or directing unlawful obtaining of the image or  
          recording, the publisher still would be potentially liable for  
          publishing or broadcasting the image or recording if it had  
          actual knowledge it had been unlawfully obtained.  This is an  
          important and strong change in the law, because, according to  
          most reports, paparazzi work independently of the direction of  
          the newspapers or other media that might publish or broadcast  
          their work product.  Indeed, the paparazzi typically sell their  
          product after the violation has been committed. 

           Background  :  In response to the tragic death of Princess Diana  
          in 1998, and other reports of outrageously overzealous paparazzi  
          endangering celebrities and members of the public, the  
          Legislature created a statutory cause of action for "invasion of  
          privacy" to supplement the common law tort of invasion of  
          privacy, and the tort of "intrusion" in particular.  Despite  
          harsh criticisms in the wake of Diana's death, and the enactment  
          of the invasion of privacy statute, "paparazzi" have nonetheless  
          continued to hunt down, and sometimes even place in serious  
          physical danger, celebrities and the public at large.  Recent  
          years have seen a flurry of news reports on the increasing  
          tension between celebrities and photographers, which at times  







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          have escalated to the point of physical confrontations and, in  
          some cases, even harassment of celebrities' children and  
          friends. 

          Defenders of the paparazzi - the numbers anecdotally appear to  
          be dwindling - claim that the problem is not the paparazzi, as  
          such, but some in the public's appetite to learn about even the  
          most mundane details of the celebrities' lives.  Others who  
          defend the ways of the paparazzi claim some of the celebrities  
          themselves "want the best of worlds," seeking out the cameras  
          when they want to bask in the limelight, and smashing those same  
          cameras on the ground when they find them annoying.  One  
          admittedly biased executive of a paparazzi news agency claimed:  
          "When a celebrity is going from the C-list to the A-list, they  
          set up the pictures," he said. "But as soon as they achieve  
          A-list status, they become artists who don't want publicity."     


          But as the author notes, the issue here is not whether the  
          paparazzi are responding to demand, or whether celebrities have  
          a more complex relationship with photographers than their  
          complaints might suggest.  Rather, the author notes that the  
          conduct of the paparazzi too often goes way beyond reasonable  
          efforts to take pictures of celebrities in public places, to  
          include intrusive and sometimes highly offensive harassment that  
          not only invades personal and familial privacy but, at times,  
          seriously endangers the public at large.  

          While the author recognizes that this bill implicates a  
          sensitive balance between the competing rights of privacy and  
          free speech, the bill's findings and declarations accurately  
          state that there is no right, under either the state or federal  
          constitutions, "to persistently follow or chase another in a  
          manner that creates a reasonable fear of bodily injury, or to  
          trespass, or to constructively trespass through the use of  
          intrusive visual or auditory enhancement."  And while this  
          measure recognizes the right of news media to gather and report  
          the news, it nonetheless appropriately finds and declares that  
          "the right of a free press to report details of an individual's  
          private life must be weighed against the rights of the  
          individual to enjoy liberty and privacy."

           Constitutional Issues: The Delicate Tension Between the First  
          Amendment and the Right to Privacy.   This important measure  
          touches the core of one of the most complex areas of  







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          constitutional law: the delicate tension between the  
          individual's right to privacy, including the right to prevent  
          disclosure of private facts, and the First Amendment that  
          protects anyone's uninhibited right to publish truthful  
          information about a matter of public concern.  For those of us  
          who live our lives in relative obscurity, the details of our  
          private lives rarely if ever become matters of public concern  
          (assuming all goes well).  But when persons voluntarily  
          interject themselves into the public arena - whether as  
          politicians, movie stars, or professional athletes - the line  
          between what is truly private and what is a matter of public  
          concern can become quite fuzzy.  For example, if Manny Ramirez  
          were not a professional baseball player, whether or not he  
          knowingly took steroids would not typically be a matter of  
          public concern that the press would have a right, or even an  
          interest, in reporting.

           AB 524 And the First Amendment  :  A long list of cases and  
          scholarly articles has commented on the tension between laws  
          that punish the disclosure of private facts - whether on the  
          basis of statute or common law - and the right to publish  
          truthful information on a matter of public concern.  In short,  
          government power to protect the privacy interests of citizens by  
          penalizing publication or authorizing causes of action for  
          publication typically if found to implicate First Amendment  
          rights directly.  (See e.g. William Prosser, Law of Torts 117  
          4th ed. 1971.) 

           Existing Case Law  :  Although the tension between privacy rights  
          and the First Amendment has generated a substantial body of case  
          law, three cases in particular (two by federal courts and one by  
          the California Supreme Court) appear to directly bear upon the  
          potential First Amendment issues raised by AB 524: in  
          particular, whether the state can "punish" the publication of  
          material that was unlawfully obtained by some other party.   
          These cases and their potential relevance for AB 524 are  
          discussed below.

           Shulman v. Group W. Productions (1998) 18 Cal 4th 200.   In  
          Shulman, decided by the California Supreme Court, the defendants  
          filmed the rescue of Ruth Shulman, who had been seriously  
          injured when her car overturned.  The film crew then equipped a  
          nurse on board a rescue helicopter with a microphone, recording  
          her conversation with the patient while en route to the  
          hospital.  The film and recordings were later broadcast as a  







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          nine-minute segment on a documentary television show called "On  
          Scene: Emergency Response."  Ms. Shulman sued the producers of  
          the TV show alleging both (1) an invasion of privacy based on  
          "intrusion" (the filming and recording), and (2) public  
          disclosure of private facts, for the subsequent broadcast. The  
          California Supreme Court upheld Ms. Shulman's claim for  
          "intrusion."  The Court was not entirely persuaded that the  
          filming of the accident, which occurred in a public place, met  
          the elements of the tort of intrusion.  However, the recording  
          of the conversation between the nurse and the patient, the Court  
          found, could meet the elements of the tort of intrusion, since  
          the court held Ms. Shulman had a reasonable expectation that,  
          once in the confines of the helicopter, her conversation with  
          the attending nurse would not surreptitiously be recorded.   
          However, as to the subsequent broadcasting of the film and tape,  
          the Court balanced the "competing" interest of Ms. Shulman's  
          privacy rights and the defendant's right to broadcast truthful,  
          "newsworthy" information.  

          On the "intrusion" claim, the Supreme Court found that a jury  
          could find that the filming, and especially the recording while  
          on the helicopter, was "highly offensive to a reasonable  
          person," and therefore overturned the trial court's summary  
          judgment in favor of the defendants.  The Court based its  
          decision in part on a finding that the "act" of newsgathering,  
          while not irrelevant to a First Amendment analysis, was not the  
          same as  publishing  the results of the newsgathering.  Thus, our  
          Supreme Court appeared to find in the Shulman case the state can  
          constitutionally punish acts of newsgathering as intrusions upon  
          privacy without offending the First Amendment, depending upon  
          the degree of offensiveness of the newsgathering technique and  
          the newsworthiness of the subject matter.  However, as to the  
          broadcasting of the incident, the Court found that the details  
          of the rescue were, as a matter of law, of legitimate public  
          concern and substantially related to the newsworthy subject of  
          the piece.  "In short," the Court concluded, "the state may not  
          intrude into the proper sphere of the news media to dictate what  
          they should publish and broadcast,  but neither may the media  
          play tyrant to the people by unlawfully spying on them in the  
          name of newsgathering  ."  (Emphasis added.)

           Turnbull v. ABC (2004) 2004 U.S. Dict. LEXIS 24351  .  The  
          distinction that Shulman makes between newsgathering (that is,  
          the actual intrusion that captures the image or recording) and  
          publication is also important in Turnbull v. ABC, another case  







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          appearing on point in evaluating the constitutionality of the  
          measure.  Turnbull was a 2004 decision by the federal U.S.  
          District for the Central District of California.  In that case,  
          a team affiliated with ABC's "20/20" program surreptitiously  
          records voices and images of plaintiffs (who were aspiring  
          actors) in connection with a story about actors who "buy" their  
          way into movie roles.  The plaintiffs brought several causes of  
          action alleging various privacy torts, including an action under  
          Civil Code Section 1708.8, the provision this bill seeks to  
          expand.  In Turnbull, the court considered the more narrow  
          question of whether the conduct engaged in by reporters (i.e.  
          illegally recording conversations) was protected by the First  
          Amendment, on the grounds that they were gathering newsworthy  
          information.  The Court concluded clearly, and potentially  
          helpfully regarding any future constitutional attack brought  
          against this bill, that "  the First Amendment does not provide  
          shelter from tortuous and criminal conduct  " and that "it is  
          beyond dispute that the publisher of a newspaper has no special  
          immunity from the application of general laws."  (Id. Citing  
          Cohen v. Cowles Media (1991) 501 U.S. 663, 699.  Emphasis  
          added.)  In particular, the Court noted that the act of  
          intrusion itself does not raise First Amendment difficulties  
          since it does not involve speech or other expression.  Rather,  
          "it occurs by virtue of the physical and mechanical observation  
          of the private affairs of another,  and not by the publication of  
          such observations  ."  (Id. Citing Time, Inc. v. Hill 1967) 385  
          U.S. 374, 389.  Emphasis added.)  

          Like Shulman, the Turnbull holding reiterates that unlawful news  
          gathering is not protected by the First Amendment.  However,  
          these cases also suggest that any publication of the  
          information, even if unlawfully gathered, typically does  
          implicate the First Amendment.  In its existing form, Civil Code  
          Section 1708.8 appears to be well within these key cases'  
                                                                                       reasoning, since the current statute punishes the intrusive  
          attempt to "capture" images and recordings, but expressly states  
          the publishing or broadcasting of such information is not in  
          itself a violation.  By punishing publishing, AB 524 would,  
          under these cases, appear to implicate the First Amendment.  But  
          this is not at all to say that the bill would necessarily, on  
          its face, violate the First Amendment, as the discussion of the  
          following case of the troika further demonstrates.

           Bartnicki v. Vopper (2001) 532 U.S. 514  .  The Bartnicki case  
          involved a review of a federal statute that appears to be in  







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          many ways quite similar to AB 524.  Specifically, Bartnicki  
          considered the validity of a provision of the federal Omnibus  
          Crime Control Act of 1986.  Section 2511(1)(a) of Title 18 of  
          U.S. Code essentially an anti-eavesdropping statute, makes it a  
          crime to intentionally intercept any wire, oral, or electronic  
          communication without consent of all the parties involved in the  
          communication.  Subdivision (c) of that same section makes it  
          unlawful to intentionally disclose the contents of such a  
          communication if the person disclosing it "knew or had reason to  
          know" that the information had been illegally obtained.  In  
          short, subdivision (c) appears to be strikingly similar to the  
          amendment proposed by AB 524, except that AB 524 adopts a  
          seemingly higher standard of "actual knowledge."  (AB 524 is  
          also more narrowly focused on intrusions attempting to capture  
          "personal and familial" activity, whereas as the federal law  
          applies to any communication.) 

          Although the holding in Bartnicki does not offer definitive  
          answers about AB 524, it does appear to highlight the parameters  
          of the debate.  In Bartnicki, an unknown person intercepted a  
          cell phone conversation between a union organizer and the  
          president of a teacher's union concerning ongoing negotiations  
          with a local school board.  During the course of this unlawfully  
          intercepted conversation, one of the parties suggested that if  
          some of the board members did not change their intransigent  
          stance, then they might have to "blow off the porches" of some  
          of their homes.  Whether this was said in seriousness or in  
          jest, the recorded conversation found its way to a local radio  
          station that played it repeatedly.  When the case reached the  
          U.S. Supreme Court the parties had stipulated to a number of key  
          issues: (1) that the conversation had been unlawfully obtained;  
          (2) that the radio station played no role in obtaining the  
          recording but did know, or had reason to know, that it had been  
          unlawfully obtained; and (3) that the federal law was a "content  
          neutral" law of general applicability.  Thus, the question  
          before the Court was not whether the statute was  facially   
          invalid but whether it was  invalidly applied.   

           The majority held that application of the statute as applied in  
          this case violated the First Amendment.  In reaching its  
          conclusion, the court reasoned that while the act of  
          intercepting the information was clearly illegal and therefore  
          unprotected, the publication of even illegally obtained  
          information is protected by the First Amendment.  Very important  
          for any constitutional analysis of this bill, however, the Court  







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          stressed that its holding could only be applied to the narrow  
          facts before them, and expressly disavowed articulating any  
          broad principles to resolve the complex competing interests at  
          stake.  In looking at the specific facts of the case, the Court  
          reasoned that there were many factors which worked in favor of  
          the radio programs First Amendment right to broadcast the  
          recording, even though it knew it was unlawfully obtained: (1)  
          it involved a matter of obvious public concern; (2) the radio  
          program had played no role in obtaining the information and had  
          done nothing to encourage the obtaining of the information; and  
          (3) the radio station had itself obtained the information  
          lawfully.  In addition, the Court rejected the government's  
          claim in support of applying the statute that the government had  
          an interest in deterring illegal activity.  The Court found the  
          deterrence argument to be weak, concluding that "it would be  
          quite remarkable to hold that speech by a law-abiding possessor  
          of information can be suppressed in order to deter conduct by a  
          non-law-abiding third party."  

          In short, the holdings and dicta in Shulman, Turnbull, and  
          Bartnicki  -- although each self-consciously limited to the  
          facts before them - appear to make two key points that appear  
          quite relevant to any constitutional analysis of this bill as it  
          proposes to amend existing law: (1) That unlawful actions do not  
          implicate the First Amendment since they are not forms of speech  
          or expression; (2) that publication of even unlawfully obtained  
          information implicates the First Amendment; but (3) that laws  
          that prohibit the disclosure of unlawfully obtained information,  
           where the one disclosing knows or has reason to know that it was  
          unlawfully obtained  , are not necessarily facially  
          unconstitutional, but may be found to be unconstitutional as  
          applied, especially where the information is of a matter of  
          genuine public concern. 

           Conclusion  :  The analysis does not purport to suggest that the  
          above case summaries address nearly all of the relevant issues  
          surrounding the constitutionally important and competing claims  
          of privacy rights and the First Amendment inherently triggered  
          by this important legislation.   However these cases - which  
          appear to be the most relevant - at least begin to set out the  
          parameters within which this bill might be evaluated purely from  
          a constitutional vantage point.  In considering the strong  
          public policy arguments in support of the measure,  the Committee  
          may wish to discuss with the author  her views as to whether it  
          might make sense as the bill moves through the Legislature to  







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          evaluate the potential merits of narrowing the bill a bit to  
          more surgically target its penalties on those persons or  
          entities that actually pay money or some other form of  
          consideration for the ill-begotten images and recordings covered  
          by the measure.  In exploring this possible narrowing, it may be  
          concluded that the bill should make crystal clear that a media  
          outlet shall continue to be permitted to publish or broadcast  
          images, perhaps captured by a citizen, that are truly  
          newsworthy, and not produced solely or primarily with the  
          expectation of financial gain. 

           ARGUMENTS IN SUPPORT  :  In support, the PAPARAZZI Reform  
          Initiative writes:


               Having worked for two decades in and around the  
               entertainment industry (spending five of those years  
               in security), I have unfortunately gotten to see  
               behind the scenes regarding how the paparazzi work and  
               I have many levels of disagreement and concern  
               regarding how they behave.



               First and foremost, it utterly stuns me that no one  
               else has been killed - paparazzo, pedestrian or  
               celebrity. With high speed car chases shooting through  
               the streets of Los Angeles with no regard for street  
               lights or other laws, it is only a matter of time  
               before disaster strikes again.



               But on another level, a more basic human level, no  
               individual deserves to be treated the way the  
               paparazzi treat most of their "subjects". Like packs  
               of wolves, they literally hunt their victims,  
               surrounding them in vehicles or on foot, following  
               them and taking photos hoping to get something they  
               can sell. Whether the celebrity wants it or not,  
               whether child involved or no, the paparazzi persist.  
               With cameras flashing and video running, they endanger  
               pedestrians, drivers, the celebrity and even  
               themselves.








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               One night not long ago I took my camera and turned  
               into a paparazzo for a few hours to get my own photos  
               of them. I became part of the pack waiting for a big  
               celebrity to walk out of a restaurant and when the  
               moment arrived, as body guards and assistants whisked  
               the celebrity to the waiting SUV, a veteran paparazzo  
               got the perfect shot of her. He came over and  
               displayed the photo on his camera and as the SUV  
               pulled away said, "God forbid this is the last photo  
               of her?you never know, she could die in an accident  
               tonight." It is this mentality that will ultimately  
               cause another death which will make headlines around  
               the world.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          PAPARAZZI Reform Initiative


           Opposition 
           
          None on file 
           
          Analysis Prepared by  :  Thomas Clark / JUD. / (916) 319-2334