## Facts

- Ronald E. Galella, a freelance photographer, repeatedly followed and photographed Jacqueline Onassis and her minor children.
- The court found a sustained pattern of aggressive conduct, including obstructing John Kennedy Jr.’s bicycle, disrupting the children at school and activities, and approaching Onassis closely in public and on the water.
- Galella sued Onassis and three Secret Service agents for false arrest, malicious prosecution, and interference with his photography business.
- The United States intervened, asserting Galella interfered with Secret Service protection of the Kennedy children under 18 U.S.C. § 3056.
- The claims against the agents were dismissed on summary judgment based on immunity for actions within the scope of their protective duties.
- Onassis counterclaimed, alleging invasion of privacy, assault, harassment, intentional infliction of emotional distress, and malicious prosecution, and sought damages and an injunction.

## Issues

1. Whether Galella’s conduct constituted actionable torts (including harassment, invasion of privacy, and assault-like intrusions) warranting damages and injunctive relief.
2. Whether Galella could recover against Onassis for false arrest and malicious prosecution arising from Secret Service actions taken during protective operations.
3. Whether injunctive restrictions on Galella’s newsgathering violated the First Amendment.
4. Whether Galella’s conduct unlawfully interfered with Secret Service duties under 18 U.S.C. § 3056, justifying injunctive relief for the United States.

## Decision

- The court dismissed Galella’s claims against Onassis after trial.
- The court granted relief on Onassis’s counterclaims, finding Galella’s conduct tortious and ordering injunctive restrictions tailored to prevent harassment and endangerment.
- The court granted injunctive relief to the United States, concluding Galella interfered with Secret Service protection of the Kennedy children under 18 U.S.C. § 3056.
- The court maintained that press status did not excuse unlawful conduct and that restraints could target dangerous and harassing behavior without barring lawful photography from a reasonable distance.

## Legal Principles

- The First Amendment does not provide an absolute privilege to commit torts or endanger others while gathering news; journalists remain subject to generally applicable laws.
- Even for public figures, permissible newsgathering has limits; persistent, physically intrusive, or threatening conduct can support tort liability and equitable relief.
- Injunctions may restrict newsgathering conduct when necessary to prevent harassment, threats to safety, or obstruction, so long as the remedy is directed at unlawful behavior rather than publication.
- Secret Service agents acting within the scope of statutory protective duties under 18 U.S.C. § 3056 are immune from tort liability for actions taken in furtherance of that mission.
- Courts may enjoin conduct that interferes with federal protective functions, including actions that create safety risks and obstruct protective operations.

## Conclusion

The court rejected a claimed press immunity for aggressive newsgathering, dismissed the photographer’s tort claims, and entered injunctions protecting Onassis and the Kennedy children and preventing interference with Secret Service duties under 18 U.S.C. § 3056.


Galella v. Onassis, 353 F. Supp. 196 (S.D.N.Y. 1972)