CACI No. 1800

[Name of plaintiff] claims that [name of defendant] violated

[his/her/nonbinary pronoun] right to privacy. To establish this claim,

[name of plaintiff] must prove all of the following:

1. That [name of plaintiff] had a reasonable expectation of privacy in

[specify place or other circumstance];

2. That [name of defendant] intentionally intruded in [specify place or

other circumstance];

3. That [name of defendant]’s intrusion would be highly offensive to a

reasonable person;

4. That [name of plaintiff] was harmed; and

5. That [name of defendant]’s conduct was a substantial factor in

causing [name of plaintiff]’s harm.

In deciding whether [name of plaintiff] had a reasonable expectation of

privacy in [specify place or other circumstance], you should consider,

among other factors, the following:

(a) The identity of [name of defendant];

(b) The extent to which other persons had access to [specify place or

other circumstance] and could see or hear [name of plaintiff]; and

(c) The means by which the intrusion occurred.

In deciding whether an intrusion is highly offensive to a reasonable

person, you should consider, among other factors, the following:

(a) The extent of the intrusion;

(b) [Name of defendant]’s motives and goals; and

(c) The setting in which the intrusion occurred.

New September 2003; Revised June 2010