Porter v. City of Royal Oak

Jansen, J.

(concurring in part and dissenting in part). I respectfully dissent from part iv of the majority opinion regarding plaintiffs claim of invasion of privacy by public disclosure of private facts. I would hold that whether the material at issue was in the legitimate interest of the public is a factual issue for the jury to resolve and should not be decided as a matter of law.

The trial court erred in granting summary disposition on the basis that the information disseminated to the media was true. This is not an element of the claim of public disclosure of private *492facts. See Beaumont v Brown, 401 Mich 80, 93-103; 257 NW2d 522 (1977); Winstead v Sweeney, 205 Mich App 664, 668; 517 NW2d 874 (1994). However, I do not agree with the majority that summary disposition is appropriate because the material disclosed was of legitimate interest to the public and was, therefore, not private as a matter of law. I believe that whether the material disclosed was of legitimate interest to the public is a factual question for the jury.

In order to sustain a claim for public disclosure of private facts, a plaintiff must show that the disclosed information is highly offensive to a reasonable person and that the information is of no legitimate concern to the public. Winstead, supra, p 668. The information published must concern the individual’s private life and must not have been a matter of public record or otherwise exposed to the public eye. Id.

Here, plaintiff had both a contractual and a statutory expectation that his internal disciplinary record would not be disclosed to the public. The collective bargaining agreement in effect at the time provided that an "employee’s files shall not be made available to any person or organization other than the employer and the employee without the employee’s expressed authorization.” Further, the Employee Right to Know Act provides that an employer shall not divulge a disciplinary report to a third party (who is not part of the employer’s organization or who is not part of the labor organization representing the employee) without written notice as provided in the statute. MCL 423.506; MSA 17.62(6).1 Therefore, plaintiff had a reason*493able expectation that his disciplinary record would not be divulged to the public.

The majority overstates that law enforcement of legitimate interest to the public and overlooks the fact that plaintiff had a statutory and contractual expectation not to have his disciplinary record exposed to the public. In Winstead, supra, p 674, this Court quoted approvingly from Virgil v Time, Inc, 527 F2d 1122, 1131 (CA 9, 1975):

The fact that [persons] engage in an activity in which the public can be said to have a general interest does not render every aspect of their lives subject to public disclosure. Most persons are connected with some activity, vocational or avocational, as to which the public can be said as a matter of law to have a legitimate interest or curiosity. To hold as a matter of law that private facts as to such persons are also within the area of legitimate public interest could indirectly expose everyone’s private life to public view.

Accordingly, I believe that plaintiff has presented sufficient evidence establishing a claim of public disclosure of private facts to withstand summary disposition. Plaintiff has set forth evidence that his disciplinary record was disclosed to the media and then broadcast through the media. Further, whether the public disclosure involves embarrassing private facts is a question of fact for the jury. Beaumont, supra, p 106; Doe v Mills, 212 Mich App 73, 81; 536 NW2d 824 (1995). Plaintiff has presented evidence that his actions during the *494Heaps incident was broadcast in a manner to embarrass and humiliate him. Doe, supra, p 82. Finally, where plaintiff had a statutory and contractual expectation not to have the disciplinary record revealed to anyone other than his union and his employer, there is a factual issue for the jury to resolve regarding whether the information disclosed was of legitimate interest to the public.

I would reverse the trial court’s order granting summary disposition in defendants’ favor regarding the public disclosure of private facts claim. Because the trial court did not address the governmental immunity claim by defendants, I would leave the question whether plaintiff has pleaded facts in avoidance of governmental immunity for the parties to resolve on remand.

With respect to the remaining aspects of the majority’s opinion, I concur.

The majority states that I have "erroneously assumefd]” that defendants violated the Employee Right to Know Act and the collective bargaining agreement. Not so. Rather, I believe that the statute and the contract gave plaintiff a reasonable expectation that his *493internal disciplinary record would not be disclosed to the public, and that whether the material disclosed is in the legitimate interest of the public is a factual question that cannot be decided as a matter of law. I further note that the trial court did not grant defendants summary disposition with respect to plaintiffs claim under the Employee Right to Know Act and that the parties eventually settled that claim. In any event, the language in the statute and in the collective bargaining agreement speaks for itself.