In a recent case from California's high court,Shulman v.Group W Productions,the court held that an accident victim might have an enforceable expectation of privacy

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The court held that an accident victim might have an enforceable expectation of privacy in conversations with medical personnel at the scene and inside a rescue helicopter. While lying motionless at the accident scene, the victim does not have a reasonable expectation of privacy as they are in a public space.

In a Recent Case from California's High Court,Shulman V