Karen Reid v. Pierce County, Respondents Cynthia Hyde-Lucas v. Pierce County, Respondents Jacquie Hyde

Summary

The court held that immediate relatives of deceased persons may maintain a common-law invasion-of-privacy action based on the appropriation and display of autopsy photographs because the conduct implicates the relatives' protectable privacy interest in preserving the deceased's dignity. It upheld dismissal or summary judgment on the relatives' negligent-infliction and outrage claims because none of the plaintiffs was present when the complained-of conduct occurred. The court declined to create a damages action directly under the state constitutional privacy provision because the common-law remedy was adequate.