## Facts

- Sally Ann Winegard filed a dissolution action against John R. Winegard; he denied any marriage.
- After a bifurcated hearing, the district court ruled the parties had a common-law marriage and summarized testimony supporting that finding.
- John sought review and attached the district court ruling to his application for leave to appeal, placing it in appellate filings.
- John also filed related proceedings in federal court and again included the ruling, further placing the information in public judicial records.
- Newspapers later published articles about the dispute, attributing statements to Sally’s attorneys describing facts consistent with the court’s common-law-marriage findings (e.g., the parties held themselves out as married; a child’s surname was changed to Winegard).
- John sued the attorneys for (1) invasion of privacy based on public disclosure of private facts and (2) defamation, relying in part on an Iowa dissolution confidentiality statute restricting access to “record and evidence” absent court order.

## Issues

1. Whether Iowa’s dissolution confidentiality statute created, or expanded, a civil damages claim for invasion of privacy based on alleged extra-judicial disclosure of dissolution information.
2. Whether facts placed in public court records by a plaintiff can remain “private” for purposes of a public-disclosure-of-private-facts claim.
3. Whether the attorneys’ alleged statements and resulting press coverage were actionable as defamation.

## Decision

- The Iowa Supreme Court affirmed summary judgment for the attorneys on both claims.
- The dissolution confidentiality statute did not create a private damages remedy and did not expand common-law privacy tort liability.
- Because John had made the relevant facts part of public judicial records through his own filings, the facts could not be treated as “private” for a disclosure-based privacy claim.
- The defamation claim failed because the challenged statements were not shown to be actionable, including where they substantially reflected court findings or were otherwise protected in the context of reporting and discussion of judicial proceedings.

## Legal Principles

- Public disclosure of private facts requires publicity of truly private information that would be highly offensive to a reasonable person and is not of legitimate public concern.
- There is no liability for publicity given to matters contained in public records; a person who voluntarily makes information public in judicial proceedings generally cannot later claim invasion of privacy based on repetition or summarization of that information.
- A statutory confidentiality restriction on inspection of court records is typically procedural; absent clear legislative intent, it does not create an implied private cause of action for civil damages.
- Accurate or substantially true summaries of judicial rulings and matters of public record generally do not support defamation liability, particularly when tied to reports or discussion of judicial proceedings.

## Conclusion

The court upheld summary judgment for the attorneys, holding that the dissolution confidentiality statute did not supply a tort damages theory and that information John placed into public court filings could not support a public-disclosure privacy claim; the related defamation claim also lacked actionable statements under the record.


Winegard v. Larsen, 260 N.W.2d 816 (Iowa 1977)