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ARTICLE · 01 JULY 2025

The Ninth Circuit Briefly Speaks On CIPA Section 631

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The Ninth Circuit recently issued two back-to-back memoranda of dispositions addressing claims under the California Invasion of Privacy Act ("CIPA") Section 631 and the common law tort of intrusion upon seclusion. First, on June 18, 2025...

United StatesPrivacy
Tony Weibell
Tony Weibell
Sophia Mancall-Bitel
Sophia Mancall-Bitel
Amber Thomson
Amber Thomson
Britteny L. Leyva
Britteny L. Leyva
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The Ninth Circuit recently issued two back-to-back memoranda of dispositions addressing claims under the California Invasion of Privacy Act ("CIPA") Section 631 and the common law tort of intrusion upon seclusion. First, on June 18, 2025, the Court affirmed the dismissal of both the intrusion upon seclusion and Section 631 claims against Papa John's International, Inc.1 Two days later, the Court again affirmed dismissal of the intrusion upon seclusion claim, but reversed the dismissal of the Section 631 claim against Bloomingdale's, LLC, holding that the plaintiff had adequately pleaded a violation of Section 631.2

Overview of CIPA Section 631 and Intrusion Upon Seclusion

California Penal Code § 631(a) prohibits the interception of communications while in transit, as well as attempts to read or learn the contents of such communications without consent. Some courts in California have interpreted Section 631(a) as "covering 'three distinct and mutually

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