These points are related. We neglected to mention Bureau of Credit Control v. The doctrine of respondeat superior is fully applicable to suits for defamation and invasion of privacy, notwithstanding the limitations that the First Amendment has been held to place on these torts. Two of the photographs are by Gregory, and one of them is of Robyn Douglass, though she is not identified by name. Although many people find Playboy, with its emphasis on sex and nudity, offensive, the differences between it and Hustler are palpable.
But the statement was dictum.
Although originally the forbidden use was putting one's name or picture into an advertisement, it is apparent from Zacchini v. A more difficult question is whether the facts of this case make out a false-light tort. Douglass was not entitled to a directed verdict. The judge gave the jury a verdict form with a blank beside each defendant's name for the amount of compensatory damages if the jury found either defendant liable, and a separate blank beside each name for punitive damages. Argued April 24, City of Berwyn, supra, F.