In Ignat v. Yum Brands, Inc. (March 18, 2013) Case No. G046343, the Fourth District Court of Appeal ruled employees can sue when their employers publicly disclose private facts about them, even if just verbally. The case started when Melissa Ignat, a Yum Brands employee, returned to work after an absence to learn that her employer had revealed to her co-workers that she suffered from bipolar disorder. She filed a lawsuit, alleging public disclosure of private facts.
The case is especially significant because the Court of Appeal abolished the requirement that disclosure happened in a document. The Court decided there was no good reason for the "document requirement" and recognized that verbal disclosures can be just as harmful and written ones. Since the requirement served no legitimate purpose, the Court allowed Ms. Ignat to sue her employer for verbally disclosing her condition to her co-workers.