The paparazzi are susceptible to tort claims of intrusion if they harass and stalk the celebrities they are seeking to photograph. A famous case of intrusion involved paparazzo Ron Galella, who relentlessly pursued former First Lady Jacqueline Onassis (Kennedy) and her children. He followed son John Jr. on his bicycle and interrupted daughter Caroline while she played tennis. Once, he got very close to a boat carrying Jackie O. in another boat to snap pictures. A federal court (Galella v. Onassis, 487 F.2d 986 [2d. Cir. 1974]) issued an injunction, ordering Galella from staying a certain distance away from Jackie O. and her children.

A reviewing federal appeals court upheld the order and finding of an invasion of privacy. “When weighed against the de minimis public importance of the daily activities of the defendant, Galella’s constant surveillance, his obtrusive and intruding presence, was unwarranted and unreasonable,” the court wrote. “If there were any doubt in our minds, Galella’s inexcusable conduct toward defendant’s minor children would resolve it.”