In Sullivan v. Pulitzer Broadcasting Co., 709 S.W.2d 475, 478
(Mo. banc 1986), the Supreme Court of Missouri noted that it has not recognized a separate cause of action for false light invasion of privacy claims. The Court declined to recognize the cause of action in Sullivan, finding that the plaintiff’s claims were merely a defamation claim. Sullivan, 709 S.W.2d at 481. But the Court did not rule out possible future recognition of false light claims as a separate cause of action. “It may be possible that in the future Missouri courts will be presented with an appropriate case justifying our recognition of the tort of...
