Yoder v. Smith

112 N.W.2d 862, 253 Iowa 505, 1962 Iowa Sup. LEXIS 617
CourtSupreme Court of Iowa
DecidedJanuary 9, 1962
Docket50491
StatusPublished
Cited by14 cases

This text of 112 N.W.2d 862 (Yoder v. Smith) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Yoder v. Smith, 112 N.W.2d 862, 253 Iowa 505, 1962 Iowa Sup. LEXIS 617 (iowa 1962).

Opinions

Oliver, J.

This is an action for damages for invasion of the right of privacy and for libel.

Division I of plaintiff’s petition alleged defendants wrote two letters to plaintiff’s employer which stated, “plaintiff was indebted on various accounts, and requested plaintiff’s employer to withhold from plaintiff’s wages.

“6. That said letters are an invasion of plaintiff’s right to be private in his personal affairs.

“7. That by reason of said communication plaintiff has been grievously injured in the eyes of his employer, his business associates and friends.

“8. That said communications were by their nature malicious and provocative, and were designed for the sole purpose of extracting money from plaintiff through plaintiff’s employer.”

[507]*507Judgment was prayed for $10,000 actual damages and $7500 punitive or exemplary damages.

Division II of the petition alleged the letters were false, “the plaintiff not being indebted in any manner to the defendants or any people they represent, and that by reason thereof said defendants communicated a false and libelous statement to the plaintiff’s employer.”

Defendants’ Motion to Dismiss the petition stated:

“1. As a matter of law an employee has no right of privacy as to his employer in regard to debts owed by the employee.
“2. As a matter of law the communications alleged by the plaintiff are not libelous statements.
“3. As a matter of law the communications alleged in plaintiff’s petition are privileged communications as to both theories of action stated by the plaintiff.”

The trial court sustained the motion to dismiss each division, on the ground:

“It appears from Division I, of the plaintiff’s Petition, that the communication was to the plaintiff’s employer only, as distinguished from the general public, and since the communication was not made to the general public, it is the opinion of the Court that Division I, of the Petition does not plead a cause of action.
« # * ®
“Division II of the plaintiff’s Petition [charging libel] does not allege malice and in view of this fact it fails to allege a cause of action.”

I. In this appeal plaintiff does not contend the dismissal of Division II of his petition, charging libel, was erroneous. Hence, only the dismissal of Division I, which charges interference with plaintiff’s right of privacy, need be considered. Interference with the right of privacy has been held actionable in this state in a case not here in point. Bremmer v. Journal-Tribune Publishing Co., 247 Iowa 817, 76 N.W.2d 762. In several states it is governed by statute.

II. Prosser, Law of Torts, 2nd Ed. 1955, 637-639, and his more recent article on Privacy in 48 California Law Rev. 389, [508]*508state there are four distinct kinds of invasions of four different interests of the plaintiff which are tied together by a common name but otherwise have almost nothing in common except that each represents an interference with the right of the plaintiff “to be let alone.” Dean Prosser lists them as follows:

“1. Intrusion upon plaintiff’s seclusion or solitude, or into his private affairs.
“2. Public disclosure of embarrassing private facts about the plaintiff.
“3. Publicity which places plaintiff in a false light in the public eye.
“4. Appropriation, for defendant’s advantage, of the plaintiff’s name or likeness.”

He points out that the first three torts in his list are primarily concerned with the protection of a mental interestj and that they are only a phase of the larger problem of the protection of peace of mind against unreasonable disturbances.

The alleged invasion here involved is numbered 2 in the foregoing list, public disclosure of embarrassing facts about the plaintiff. Of such an invasion, Dean Prosser states, 48 California Law Rev., 393 and 394:

“First, the disclosure of the private facts must be a public disclosure, and not a private one. There must be, in other words, publicity. It is an invasion of the right to publish in a newspaper that the plaintiff does not pay his debts, or to post a notice to that effect in a window on a public street or cry it aloud in the highway; but, except for one decision of a lower Georgia court which was reversed on other grounds, it has been agreed that it is no invasion to communicate that fact to the plaintiff’s employer, or to any other individual, or even to a small group, unless there is some breach of contract, trust or confidential relation which will afford an independent basis for relief.”

Decisions of various courts support this statement. Some eases in which the giving of undue publicity to private debts has been held to constitute an invasion of the debtor’s right of privacy are cited in an annotation in 138 A. L. R. 22 at page 91. In Brents v. Morgan, 221 Ky. 765, 299 S.W. 967, 55 A. L. R. [509]*509964, a large sign in a public place stated plaintiff owed an old account there, and in Trammell v. Citizens News Co., 285 Ky. 529, 148 S.W.2d 708, plaintiff’s indebtedness was published in a newspaper.

Almost all decisions on the point agree it is not an actionable invasion of a debtor’s right of privacy for one, attempting to collect a bill, to communicate to the debtor’s employer the fact of his debt. Most of these decisions are cited in Gouldman-Taber Pontiac, Inc. v. Zerbst, 213 Ga. 682, 683, 100 S.E.2d 881, 882, which states:

“Whether a letter written by a creditor to an employer notifying him that his employee is indebted to the creditor, and seeking the employer’s aid in the collection of the debt constitutes a violation of the right of privacy of the employee, is a question of first impression in this State. Courts of other jurisdictions in dealing with the question have generally held that such does not give a cause of action for a violation of the right of privacy, their reasoning being that, in giving this information to an employer, it was not giving to the general public information concerning a private matter in which it had, or could have, no legitimate interest, since an employer has a natural and proper interest in the debts of his employees. Voneye v. Turner [Ky., 240 S.W.2d 588(3)]; Patton v. Jacobs, 118 Ind. App. 358, 78 N.E.2d 789 [cited by the trial court in the case at bar]; Lewis v. Physicians & Dentists Credit Bureau, Inc., 27 Wash. 2d 267, 177 P.2d 896; McKinzie v. Huckaby, D. C., 112 F. Supp. 642; Housh v. Peth [165 Ohio St. 35, 133 N.E.2d 340] ; Hawley v. Professional Credit Bureau, Inc., 345 Mich. 500, 76 N.W.2d 835.

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Bluebook (online)
112 N.W.2d 862, 253 Iowa 505, 1962 Iowa Sup. LEXIS 617, Counsel Stack Legal Research, https://law.counselstack.com/opinion/yoder-v-smith-iowa-1962.