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1527 REVIEW GRANTED If surreptitiously photographing or videotaping a plaintiff is tortious, it is as an invasion of seclusion, for which liability can not be imposed unless plaintiff had an objectively reasonable expectation of privacy in the circumstances; there is no sub-tort known as violation of the right to be free of photographic invasion.CitationSANDERS v ABC (Tele Psychic) 52 CA4 543 [See: Hill v NCAA 7 C4 1; Sacramento v Sacramento 51 CA4 1468, T/AT 2/97; Shulman v Group W 51 CA4 850, T/AT 2/97]
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