Medical Laboratory Management Consultants v. American Broadcasting Companies, Inc.

Medical Laboratory Management Consultants (“Medical Lab”) and John Devaraj (“Devaraj”), a founder and owner of Medical Lab, (collectively “Plaintiffs”) brought this action against American Broadcasting Companies (“ABC”) and individuals allegedly involved in producing the segment Rush to Read for ABC’s television program PrimeTime Live (collectively “Defendants”). The district court, exercising diversity jurisdiction under 28 U.S.C. § 1332 , granted summary judgment in Defendants’ favor on Devaraj’s claim of intrusion upon his seclusion, Medical Lab’s claims of trespass and tortious interference with contractual relations and prospective economic relations, and Plaintiffs’ claims for punitive damages. Plaintiffs now appeal the district court’s resolution of these claims. We have jurisdiction under 28 U.S.C. § 1291 over Plaintiffs’ timely appeal of the district court’s judgment, which the court entered pursuant to Federal Rule of Civil Procedure 54(b). For the reasons set forth below, we affirm.

FACTS AND PROCEDURAL BACKGROUND

This action arises out of the videotaping and broadcast of a television segment enti- *810 tied Rush To Read for ABC’s television program’…