Missouri

Missouri has recognized intrusion, false light, and misappropriation claims but has questioned the false light tort. Sullivan v. Pulitzer Broadcasting Co., 709 S.W.2d 475 (Mo. 1986).

Intrusion: Even though an enormously obese hospital patient granted an interview to a reporter and talked about her illness, she did not give the reporter permission to use her name or photograph, and when her name and photograph were published, she had grounds for an invasion of privacy suit. Barber v. Time, Inc., 159 S.W.2d 291 (Mo. 1942).

An undercover television reporter who entered a hospital’s alcohol treatment center by pretending to be an alcoholic did not commit intrusion against the hospital because corporations have no right of privacy. W.C.H. of Waverly v. Meredith Corp., 13 Med. L. Rptr. 1646 (W.D. Mo. 1986).

Private Facts: Television footage of a person with his hands on top of a police car during an erroneous arrest did not disclose any private facts because the arrest did not disclose any private facts because the arrest was a matter of legitimate public interest, and the film was shot in a public place. Williams v. KCMO, 472 S.W.2d 1 (Mo. 1971).

A couple videotaped at a hospital function and identified as participants in an in vitro fertilization program stated a claim for publication of private facts.” Y.G. v. Jewish Hospital of St. Louis, 1990 WL 99335 (Mo. Ct. App. July 12, 1990).

False Light:A photograph taken during a sheriff’s drug raid that showed a sign bearing the name of a Christmas-tree farm did not portray the farm’s owner in a false light, even though he was not the subject of the raid, and no drugs were found on his property. Police activities are a matter of public interest and cannot be the basis for a false light claim. The article accompanying the photo did not mention the landowner’s name, as it reported only the names of people involved in the raid. Hagler v. Democrat-News, 699 S.W.2d 96 (Mo. Ct. App. 1985).