Jackson v. Mayweather
2017 Cal. App. LEXIS 366, 217 Cal. Rptr. 3d 234, 10 Cal.App.5th 1240 (2017)
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Rule of Law:
While the private lives of public figures are generally considered newsworthy and protected speech, the publication of sensitive medical documents like a sonogram is not newsworthy and constitutes an actionable invasion of privacy if it serves no legitimate public purpose and amounts to morbid and sensational prying. A defamation claim will fail if the challenged statement is substantially true, meaning any inaccuracies do not alter the substance, gist, or sting of the charge.
Facts:
- Shantel Jackson and Floyd Mayweather, Jr., both public figures, were in a highly-publicized, long-term romantic relationship which at one point included an engagement.
- Jackson alleged that Mayweather was physically and verbally abusive throughout their relationship.
- In November 2013, Jackson became pregnant with twins by Mayweather and gave him a copy of the sonogram at his request.
- In January 2014, Jackson's pregnancy was terminated.
- After the relationship ended, Jackson began seeing another celebrity, posting a picture of them together on social media.
- On May 1, 2014, Mayweather posted on his Facebook and Instagram accounts that the real reason he and Jackson broke up was because she "got an abortion," which he was "totally against killing babies."
- Along with this statement, Mayweather publicly posted a copy of the sonogram of the twin fetuses and a summary medical report regarding the pregnancy.
- The following day, Mayweather stated in a radio interview that Jackson had undergone extensive cosmetic surgery procedures on her face and body.
Procedural Posture:
- Shantel Jackson filed a complaint against Floyd Mayweather, Jr. in California superior court (trial court) alleging multiple causes of action, including invasion of privacy and defamation.
- Mayweather filed a special motion to strike five of the causes of action pursuant to California's anti-SLAPP statute, section 425.16.
- The trial court found that Mayweather's conduct constituted protected activity but that Jackson had established a probability of prevailing on her claims.
- The trial court denied Mayweather's special motion to strike.
- Mayweather, as the appellant, appealed the trial court's order to the California Court of Appeal. Jackson is the appellee.
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Issue:
Did the trial court err in denying a public figure's special motion to strike claims for public disclosure of private facts, defamation, and false light, where the claims were based on his social media posts revealing his former partner's abortion, a sonogram, and statements about the reasons for their breakup and her cosmetic surgery?
Opinions:
Majority - Perluss, P. J.
Yes, in part. The trial court erred by not striking the defamation and false light claims, as well as the portion of the public disclosure claim related to the fact of the abortion and cosmetic surgery, but correctly allowed the public disclosure claim based on the publication of the sonogram and medical report to proceed. The court reasoned using a two-step analysis. First, Mayweather's statements were made in a public forum (social media/radio) about an issue of public interest, since the lives of high-profile celebrities qualify as such. Second, the burden shifted to Jackson to show a probability of prevailing. For public disclosure of private facts, the court found that the topics of the abortion and cosmetic surgery were newsworthy given the parties' celebrity status, barring the claim for those disclosures. However, the publication of the sonogram and medical report was not newsworthy; it was a 'morbid and sensational' prying into her private life that served no legitimate public purpose. For defamation, Jackson failed to prevail because Mayweather’s statement about the reason for the breakup was not defamatory (the reputational harm came from the abortion, which was true, not the reason for the breakup) and his statements about her cosmetic surgery were substantially true, as minor exaggerations do not constitute falsity. The false light claim failed because it was superfluous to and dependent on the failed defamation claim.
Analysis:
This case provides a significant clarification on the limits of the 'newsworthiness' defense in invasion of privacy claims involving public figures in the age of social media. The court draws a critical line between the public's interest in the facts of a celebrity's life (e.g., that an abortion occurred) and the public's interest in their private medical records (e.g., a sonogram). This holding establishes that while public figures have a diminished expectation of privacy, they do not forfeit it entirely, particularly concerning highly sensitive, graphic, or intimate documentation. The decision reinforces that there is a boundary where celebrity gossip becomes 'morbid and sensational prying,' which is not protected speech, thereby providing a crucial precedent for future privacy cases against public figures who use social media to disclose intimate details.
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