California, United States of America
The following excerpt is from Shulman v. Group W Productions, Inc., 51 Cal.App.4th 850, 59 Cal.Rptr.2d 434 (Cal. App. 1996):
Finally, to the extent that appellants' predicate their privacy claims on respondents' alleged violation of the Penal Code section 632 proscription against electronic eavesdropping or videotaping, such a claim requires that the victim have had a reasonable expectation of privacy surrounding their conversation or communication (O'Laskey v. Sortino (1990) 224 Cal.App.3d 241, 248, 273 Cal.Rptr. 674), and we have already held that no such expectation existed at the accident scene itself.
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