Planned Parenthood Golden Gate v. Superior Court
California Court of Appeal
99 Cal. Rptr. 2d 627 (2000)
Rossi Foti (plaintiff), an anti-abortion protester, sued Planned Parenthood Golden Gate (defendant), alleging its clinic escorts interfered with his sidewalk protests, and sought through discovery the names, addresses, and phone numbers of Planned Parenthood staff and volunteers with knowledge of the case; Planned Parenthood objected on privacy grounds and offered to identify individuals by pseudonym, facilitate contact through its office, and accept service on their behalf. The trial court instead ordered disclosure under a protective order allowing litigation-only use of names and attorneys'-eyes-only access to addresses and phone numbers, and Planned Parenthood appealed.
Whether a protective order may compel disclosure of information infringing on the constitutionally protected right to privacy only if competing interests justify the type and amount of privacy invasion being compelled.