BILL ANALYSIS                                                                                                                                                                                                    �






                             SENATE JUDICIARY COMMITTEE
                         Senator Hannah-Beth Jackson, Chair
                              2013-2014 Regular Session


          AB 2643 (Wieckowski)
          As Amended June 9, 2014
          Hearing Date: June 17, 2014
          Fiscal: Yes
          Urgency: No                           
          RD


                                        SUBJECT
                                           
          Invasion of Privacy: Distribution of Sexually Explicit Materials

                                      DESCRIPTION  

          This bill would create, subject to certain exceptions, a new  
          basis for civil liability for the non-consensual and intentional  
          distribution of intimate images where the person in those images  
          had a reasonable expectation of privacy, the defendant knew that  
          the other person had a reasonable expectation that the material  
          would remain private, and the person suffers either general  
          damages or special damages, as specified. The bill would protect  
          third parties from civil liability where the distributed  
          material was previously distributed by another person, and would  
          otherwise exempt defendants from civil liability in certain  
          circumstances, such as where the person appearing in the  
          material waived any reasonable expectation of privacy in the  
          distributed material by making it accessible to the general  
          public.   

          The bill would authorize, in addition to any other relief  
          available at law, equitable relief against the person in  
          violation of this bill, including a temporary restraining order,  
          or a preliminary or permanent injunction, as specified, and  
          would provide for attorney's fees and costs for the prevailing  
          party.  

                                      BACKGROUND  

          "Revenge porn" has received national attention in recent years,  
          with legislation being proposed throughout the various states to  
          address this unfortunate phenomenon. As described by the  
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          National Conference of State Legislatures (NCSL), revenge porn  
          is the posting of nude or sexually explicit photographs or  
          videos of people online without their consent, even if the  
          photograph itself was taken with consent. It can be as a result  
          a spurned spouse, girlfriend, or boyfriend who seeks to get  
          revenge by uploading photographs to websites, many of which are  
          set up specifically for these kinds of photos or videos.  (NCSL,  
          State "Revenge Porn" Legislation (May 30, 2014)  
           [as of Jun. 11,  
          2014].)  It can also be as a result of the acts of a person who  
          hacks into a personal computer and then releases the photographs  
          or videos.  The victim's name, address, and links to social  
          media profiles are often included with the images, and some Web  
          sites charge a fee to have the materials removed.  

          Accordingly, last year, SB 255 (Cannella, Ch. 466, Stats. 2013)  
          made it unlawful in California for any person who photographs or  
          records by any means the image of the intimate body part or  
          parts of another identifiable person, under circumstances where  
          the parties agree or understand that the image shall remain  
          private, to subsequently distribute the image taken, if there  
          was intent to cause serious emotional distress and the depicted  
          person suffers serious emotional distress.  A person who commits  
          this crime is guilty of a disorderly conduct misdemeanor.  (Pen.  
          Code Sec. 947(j)(4)(A).) 

          This bill would create a new basis for civil liability for the  
          intentional distribution of intimate images where a victim had a  
          reasonable expectation of privacy, did not consent to  
          distribution, and was harmed as a result of the distribution, as  
          specified.  This remedy would be available in addition to the  
          available remedies at law. 

                                CHANGES TO EXISTING LAW
           
           Existing law  makes any person who photographs or records by any  
          means the image of the intimate body part or parts of another  
          identifiable person, under circumstances where the parties agree  
          or understand that the image shall remain private, and the  
          person subsequently distributes the image taken, with the intent  
          to cause serious emotional distress, and the depicted person  
          suffers serious emotional distress, guilty of disorderly  
          conduct, a misdemeanor.  (Pen. Code Sec. 947(j)(4)(A).) Existing  
          law defines "intimate body part" for these purposes to mean any  
          portion of the genitals, and in the case of a female, also  
                                                                      



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          includes any portion of the breasts below the top of the areola,  
          that is either uncovered or visible through less than fully  
          opaque clothing.  (Pen. Code Sec. 947(j)(4)(B).)

           Existing law  provides, besides the personal rights mentioned or  
          recognized in the Government Code, every person has, subject to  
          the qualifications and restrictions provided by law, the right  
          of protection from bodily restraint or harm, from personal  
          insult, from defamation, and from injury to his personal  
          relations.  (Civ. Code Sec. 43.)

           Existing law  provides that every person is bound, without  
          contract, to abstain from injuring the person or property of  
          another, or infringing upon any of his or her rights.  (Civ.  
          Code Sec. 1708.)  Existing case law provides that, in general,  
          if a voluntary act, lawful in itself, may naturally result in  
          the injury of another, or in the violation of his legal rights,  
          the actor must at his peril see to it that such injury or  
          violation does not follow, or he must expect to respond in  
          damages therefor, regardless of the motive or degree of care  
          with which the act is performed.  (McKenna v. Pacific E. R. Co.  
          (1930) 104 Cal. App. 538, 542 (internal citation omitted).)
           Existing law  provides for torts of domestic violence, stalking,  
          physical and constructive invasion of privacy. (Civ. Code Secs.  
          1708.6, 1708.7, 1708.8.) 

           Existing law  , with respect to an action for libel, in relevant  
          part, defines "general damages" as damages for loss of  
          reputation, shame, mortification and hurt feelings and    
          "special damages" as all damages which plaintiff alleges and  
          proves that he has suffered in respect to his property,  
          business, trade, profession or occupation, including such  
          amounts of money as the plaintiff alleges and proves he has  
          expended as a result of the alleged libel, and no other.  (Civ.  
          Code Sec. 48a(4)(a)-(b).)

           This bill  would allow for a new private cause of action against  
          a person who intentionally distributes by any means a  
          photograph, film, videotape, recording, or any other  
          reproduction of another, without the other's consent, if (1) the  
          person knew that the other person had a reasonable expectation  
          that the material would remain private, (2) the distributed  
          material exposes an intimate body part of the other person, or  
          shows the other person engaging in an act of intercourse, oral  
          copulation, sodomy, or other act of sexual penetration, and (3)  
          the other person suffers general or special damages as described  
                                                                      



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          above.

           This bill  would define "intimate body part" to mean any portion  
          of the genitals, and, in the case of a female, also includes any  
          portion of the breast below the top of the areola, that is  
          uncovered or visible through less than fully opaque clothing.

           This bill  would provide that there shall be no liability on the  
          part of the person distributing material under any of the  
          following circumstances:
           the distributed material was created under an agreement by the  
            person appearing in the material for its public use and  
            distribution or otherwise intended by that person for public  
            use and distribution;
           the person possessing or viewing the distributed material has  
            permission from the person appearing in the material to  
            publish by any means or post the material on an Internet Web  
            site;
           the person appearing in the material waived any reasonable  
            expectation of privacy in the distributed material by making  
            it accessible to the general public;
           the distributed material constitutes a matter of public  
            concern;
           the distributed material was photographed, filmed, videotaped,  
            recorded, or otherwise reproduced in a public place and under  
            circumstances in which the person depicted had no reasonable  
            expectation of privacy;
           the distributed material was previously distributed by another  
            person.

           This bill  would authorize a court, in addition to any other  
          relief available at law, to order equitable relief against the  
          person violating this bill, including a temporary restraining  
          order, or a preliminary injunction or a permanent injunction  
          ordering the defendant to cease distribution of material.  The  
          court may grant injunctive relief substituting a pseudonym for  
          the true name of the plaintiff, as specified.  The bill  
          specifies processes for the use of a pseudonym, placing  
          responsibility solely upon the parties and their counsel to  
          redact the plaintiff's name from all documents filed with the  
          court. The Judicial Council would be required to develop, by  
          July 1, 2015, the confidential information form required for the  
          use of a pseudonym.

           This bill  would authorize a court to grant, after holding a  
          properly noticed hearing, reasonable attorney's fees and costs  
                                                                      



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          to the prevailing party.

           This bill  would provide that nothing in this bill shall be  
          construed to alter or negate any rights, obligations, or  
          immunities of an interactive service provider, as defined under  
          federal law.  The bill would also provide that nothing in this  
          bill shall be construed to limit or preclude a plaintiff from  
          securing or recovering any other available remedy.

           This bill  contains a severability clause, and a delayed  
          operative date of July 1, 2015.   

                                        COMMENT
           
          1.    Stated need for the bill  

          According to the author:

            The purpose of AB 2643 is to create a clear, focused civil  
            remedy for victims of non-consensual distribution of intimate  
            images, including a temporary restraining order, injunctive  
            relief and a pseudonymous pleading provision.

            Research completed by University of Maryland Professor  
            Danielle Keats Citron and the Cyber Civil Rights Initiative  
            shows that at least 90 [percent] of the victims of  
            non-consensual distribution of intimate imagery are women.  
            This research further found that one-in-ten former intimate  
            partners have threatened to expose their ex by sharing  
            intimate images of their ex online.  Of those who threaten  
            this, 60 [percent] follow through with the threat. Of that 60  
            [percent], 59 [percent] share their ex's full name, 26  
            [percent] include her email address, 16 [percent] include a  
            home address, and 14 [percent] include the victim's work  
            address. This non-consensual distribution degrades,  
            emotionally harms and severely embarrasses the victims.  It  
            guarantees reputational harm and frequently affects employment  
            status or prospects.  It further creates a substantial safety  
            risk for many of the women victims, 49 [percent] report they  
            were harassed or stalked by people who saw the revenge porn  
            post. 

            Despite the increasing frequency of such devastating  
            distribution, the law has not caught up with non-consensual  
            distribution of intimate imagery.  Last year SB 255 (Cannella)  
            made the first steps to address the issue by creating a  
                                                                      



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            criminal penalty for distributing intimate images without  
            consent in certain circumstances.  However, there are still  
            instances where the criminal law would not apply to a  
            non-consensual distribution situation.  There are also victims  
            who do not want to approach the situation from a criminal  
            justice standpoint.  Currently, there is still no clear path  
            to a civil remedy for victim[s].  Intentional infliction of  
            emotional distress, invasion of privacy, public disclosure of  
            private facts, or other common law tort claims do not clearly  
            fit the form of conduct involved.  Nor do they provide for  
            pseudonymous filing that prevents further harm, embarrassment,  
            or risk of harassment or physical attack that comes from the  
            intimate images and victim's information becoming part of the  
            public court record when the victim files the civil suit.   
            Currently, if a victim is willing to file a civil suit despite  
            the risks, they typically must assert multiple claims hoping  
            one will "stick" with that particular court.

            This bill provides a direct, private right of action that  
            fights the particulars of non-consensual distribution of  
            intimate imagery.  It protects victims from further  
            embarrassment and potential harassment by providing an option  
            for pseudonymous filing.  The bill explicitly provides for  
            equitable relief in the form of a temporary restraining order,  
            a preliminary injunction, or a permanent injunction ordering  
            the defendant to remove the distributed images.  This  
            addresses the primary objective of most victims who simply  
            want their private images taken down. Thus, this solves the  
            non-consensual distribution of intimate images problem by  
            creating a clear pathway for victims seeking legal justice  
            when a former intimate partner has betrayed their trust and  
            caused serious harm and embarrassment through the distribution  
            of intimate images.

          Also in support, the California Partnership to End Domestic  
          Violence adds that while these pictures were most commonly taken  
          during the course of a romantic relationship and were meant to  
          be kept private, in some cases the images were acquired without  
          the consent of the subject.  "No matter the origin, victims of  
          revenge porn face embarrassment that seemingly has no end and  
          has led to dire consequences, such as alienation, loss of  
          employment, and even suicide. Many survivors of domestic  
          violence have experienced this specific abuse tactic. It is  
          especially common when the victim has left the relationship, and  
          as an attempt to exact revenge and exert power over the victim,  
          an abuser will post extremely personal pictures of a sexually  
                                                                      



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          charged nature. [ . . . ] By providing a private right of  
          action, AB 2643 empowers victims with an option for getting the  
          images out of the public eye as quickly as possible, and allows  
          for the victim to obtain relief and justice for these acts."

           2.  The proposed private right of action is predicated upon  
            distribution in violation of a reasonable expectation of  
            privacy, not distribution of an otherwise lawful image  

          This bill would create a new cause of action premised upon the  
          non-consensual, intentional distribution of specified items  
          depicting an intimate body part of another person, where (1) the  
          other person had a reasonable expectation of privacy, (2) the  
          defendant knew that the person had a reasonable expectation that  
          the material would remain private, and (3) the person in the  
          image suffered specified harm as a result of the non-consensual  
          distribution.  In terms of the last element, relating to harm  
          caused to the plaintiff, the plaintiff need only show harm that  
          satisfies general damages or special damages as those terms are  
          used under libel law in California, opposed to the more  
          stringent "severe emotional harm" standard used in intentional  
          infliction of emotional distress tort cases.  Accordingly,  
          pursuant to this bill, the plaintiff can recover damages  
          suffered in respect to his or her property, business, trade,  
          profession or occupation, including such amounts of money as the  
          plaintiff alleges and proves he or she has expended as a result  
          of the violation (special damages), but can also recover damages  
          for loss of reputation, shame, mortification, and hurt feelings  
          (general damages).  In terms of remedies, the bill allows courts  
          to grant equitable relief against the person in violation of  
          this bill, including a temporary restraining order, or a  
          preliminary or permanent injunction ordering the defendant to  
          cease distribution of material.  

          In support of the bill, the Cyber Civil Rights Initiative (CCRI)  
          writes that "[r]evenge porn, or non-consensual pornography, has  
          unfortunately become an epidemic in the United States and around  
          the world.  In most cases today, revenge porn is posted to the  
          Internet; a place where perpetrators can hide behind the cloak  
          of anonymity, and cause victims the most harm with the least  
          amount of effort.  With the click of a button, perpetrators can  
          send victims' lives spiraling out of control leaving them in a  
          state of hopelessness, despair, and sometimes severe paranoia."   
          CCRI notes that victims can also experience the loss of a job  
          and/or difficulty finding a job, the loss of a partner, the loss  
          of respect of their loved ones, can fear leaving their homes and  
                                                                      



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          can even feel unsafe in their own home.  On top of all this,  
          "[v]ictims often feel they have no recourse when they discover  
          their intimate images have been distributed without consent.   
          They are not sure what to call what has happened to them; they  
          are afraid what taking legal action will mean even greater  
          exposure, and they are not sure that the benefit of the process  
          would be.  This bill helps with all three of these burdens [ . .  
          . ] by giving this harm a name, a safe process, and a specific  
          remedy. 

          3.    Bill authorizes pseudonyms to prevent further victimization  
            of the plaintiff and encourage them to obtain relief for their  
            injuries in the courts  

          This bill would authorize a court to grant injunctive relief  
          substituting a pseudonym for the true name of a plaintiff.  A  
          plaintiff would be permitted to proceed using a pseudonym  
          (specifically, either as John Doe, Jane Doe, or Doe), for his or  
          her true name and to exclude or redact from all pleadings and  
          documents filed in the action his or her other identifying  
          characteristics.  These characteristics would include, for  
          example, the plaintiff's name, address, age, race, or  
          relationship to defendant.  A plaintiff who proceeds under a  
          pseudonym, would have to file with the court and serve upon the  
          defendant a confidential information form for this purpose that  
          includes the plaintiff's name and other identifying  
          characteristics excluded or redacted. Pursuant to the bill's  
          pseudonym provisions, the court would be required to keep the  
          plaintiff's name and excluded or redacted characteristics  
          confidential and all court decisions, orders, petitions, and  
          other documents, including motions and papers filed by the  
          parties, would be required to be worded so as to protect the  
          name or other identifying characteristics of the plaintiff from  
          public revelation.  Significantly, to reduce any potential  
          burdens on the courts, the bill would place the responsibility  
          for excluding or redacting the plaintiff's identifying  
          characteristics from all documents filed with the court solely  
          with the parties and their attorneys, and states that the bill  
          does not obligate the court to review pleadings or other papers  
          for compliance.

          As a matter of public policy, because the public has a First  
          Amendment right to access records, the use of pseudonyms in  
          cases should be the exception, not the rule. However, there is  
          precedent under California law for doing so in certain cases to  
          safeguard the individual privacy and prevent harassment,  
                                                                      



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          including cases involving victims of sexual offenses and in  
          cases where the courts find it necessary to safeguard the  
          individual privacy and prevent harassment of a health care  
          patient, licensed health practitioner, or employee, client, or  
          customer of a health care facility who is a party or witness in  
          the proceeding.  (See Pen. Code Secs. 293, 293.5; Civ. Code Sec.  
          3427.3; see also Health & Saf. Code Sec. 120291, allowing for  
          victims of intentional HIV infections to use pseudonyms.)  While  
          some might argue that such cases are arguably distinguishable  
          from the types of offenses addressed by this bill, it could be  
          said that the intentional distribution of an intimate image of  
          another person who specifically expressed desire to keep the  
          image private or who reasonably expected it would be kept  
          private by a person they trusted, is an offense upon that  
          person's body not unlike a sexual assault.  Indeed, one  
          supporter of this legislation, the Cyber Civil Rights  
          Initiative, specifically notes that "[r]evenge porn is a form of  
          sexual abuse.  It is the use of sex to control and humiliate the  
          victim.  Based upon our conversations with thousands of victims  
          around the world, revenge porn victims suffer many of the same  
          symptoms that victims of rape experience:  numbing, nightmares,  
          depression, anxiety, sudden changes in appetite, sleep  
          disturbance, suicidal thoughts, feelings of  
          guilt/shame/self-blame, poor concentration, and post-traumatic  
          stress."  It can also result in loss of employment or potential  
          employment. 

          In support of the bill, Women Escaping a Violent Environment  
          (WEAVE) writes that the option to file claims pseudonymously is  
          "vital because otherwise many victims will not bring forth  
          claims for fear of drawing further public attention to the  
          images."  Also in support of the bill, the California Employment  
          Lawyers Association (CELA) adds that non-consensual distribution  
          not only "degrades, emotionally harms and severely embarrasses  
          the victims" but "it guarantees reputational harm and frequently  
          affects employment status or prospects."  CELA writes:

            In addition, victims who are also litigants in an employment  
            lawsuit against their employers, particularly in sexual  
            harassment cases, are vulnerable to intimidation tactics by  
            employers defending the lawsuit. Employer defendants will  
            often search for embarrassing evidence against the employee  
            plaintiff, such as intimate images which are intended to be  
            private, in order to retaliate and to use them in a public  
                                                       forum (whether in court or some other public forum) as a  
            tactic to discredit the employee, defend their actions, or  
                                                                      



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            humiliate them to the point that they feel compelled to  
            dismiss their case.

            Despite its increasing frequency, the law has not caught up  
            with non-consensual distribution of intimate imagery.   
            Currently, there is still no clear path to a civil remedy for  
            victims. Intentional infliction of emotional distress,  
            invasion of privacy, public disclosure of private facts, or  
            other common law tort claims do not clearly fit the form of  
            conduct involved.  Nor do they provide for pseudonymous filing  
            that prevents further harm, embarrassment, or risk of  
            harassment or physical attack that comes from the intimate  
            images and victim's information becoming part of the public  
            court record when the victim files the civil suit.

          Accordingly, by providing for the use of pseudonyms, this bill  
          appears to remove a disincentive from bringing legitimate  
          lawsuits and also address issues such as employer retaliation.   
          While such helpfulness is arguably tampered by the reality that  
          once photographs or videos or other intimate images or sounds  
          are made available on the Internet, little if anything can be  
          done to remove the previously distributed images, this bill, at  
          the very least, helps plaintiffs prevent the future distribution  
          of those images. 

          4.    Attorney's fees
           
          This bill would allow for a court to grant, upon a properly  
          noticed hearing, attorney's fees and costs to a prevailing party  
          in an action brought under this bill.  This could  
          unintentionally serve as a deterrent to victims to bring suits,  
          as they could be required to bear the costs of the defendant if,  
          for whatever reason, they fail to prove one of the elements of  
          this proposed tort.  

          The following amendment would allow for the prevailing plaintiff  
          (i.e. the victim) to recover attorney's fees, while removing any  
          deterrence for victims to bring claims as a result of a two way  
          shifting fee.  

             Suggested amendment  :  
             
            On page 5, line 24, strike "party" and insert "plaintiff" 

          5.    Author's amendments  

                                                                      



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          The author offers the following amendments that would: (1)  
          correct a drafting error and ensure the burden of implementing  
          the pseudonym provisions falls on the parties and their counsel,  
          and not on the courts; and (2) strike the provision to require  
          counsel for all parties to comport their conduct with a  
          specified rule of professional conduct and require that counsel  
          and all parties comply with any lawful order of the court.  

             Author's amendments  : 

            (1):  On page 5, lines 19-21, strike "The court may grant  
            injunctive relief substituting a pseudonym for the true name  
            of the plaintiff pursuant to subdivision (e)" and insert "The  
            court may grant injunctive relief maintaining the  
            confidentiality of a plaintiff using a pseudonym as provided  
            in subdivision (f)"

            (2):  On page 6, strike lines 1-4, inclusive and renumber  
            accordingly

            6.   Removal of opposition  

          Based upon the June 9 amendments to the bill, the American Civil  
          Liberties Union has removed its opposition to the bill and is  
          now neutral. 


           Support  :  Attorney General Kamala Harris; California Employment  
          Lawyers Association; California Partnership to End Domestic  
          Violence; Consumer Attorneys of California; Cyber Civil Rights  
          Initiative; Democratic Activists for Women Now;
          McGeorge Women's Caucus; Peace Officers Research Association of  
          California (PORAC); Women Escaping a Violent Environment  
          (WEAVE); two individuals

           Opposition  :  None Known

                                        HISTORY
           
           Source  :  Author

           Related Pending Legislation  :  None Known

           Prior Legislation  :  SB 255 (Cannella, Ch. 466, Stats. 2013) See  
          Background.

                                                                      



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           Prior Vote  :

          Assembly Floor (Ayes 75, Noes 0)
          Assembly Appropriations Committee (Ayes 17, Noes 0)
          Assembly Judiciary Committee (Ayes 10, Noes 0)

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