A creditor put his claim into the hands of one Power, who held himself out as an advertiser of accounts for sale. Power threatened several times by letter to advertise the debtor's account for sale at auction unless it was paid immediately. No payment was made; and a "flaming orange handbill" was printed and circulated about the debtor's neighborhood. It offered for sale to the highest bidder the debtor's and twenty-three other accounts. It contained, further, the statement that all accounts were guaranteed correct and undisputed and a solicitation for merchants' accounts to be similarly disposed of. Thereupon the debtor sued his creditor (1) for libel and (2) for violation of his right of privacy, The existence of the debt was not disputed. Held, the right of privacy did not exist at common law; and the handbills were not actionable as libel without proof of special damages. Judevine v. Benzies-Montanye Fuel Co., 222 Wis. 512, 269 N. W. 295 (1936).
Gerald M. Stevens,
LIBEL - RIGHT OF PRIVACY -AUCTION SALE OF DEBTS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol36/iss2/14