West v. Media General Convergence, Inc.

A television station owned by Media General Convergence (defendant) aired a story implying that West's probation-referral business was illegal and that she had an improper relationship with a judge. West sued for defamation and false-light invasion of privacy, and the federal court hearing the case certified to the Tennessee Supreme Court whether the state recognized the false-light tort and, if so, its elements.

Whether most jurisdictions recognize false-light invasion of privacy as a separate, actionable tort distinct from defamation, and if so, what standard governs it for private-figure claimants.