Woolsey v. Judd (1855) 4 Duer (N.Y.) 379 Baker v. Libbie (1912) 210 Mass. 599, 97 N.E. 109, 37 L.R.A. (N.S.) 944 Hearst v. Black (1936) 87 Fed. 268 34 American Jurisprudence '' 14, 15, 16 & 20 51 L.R.A. 360, note. 37 L.R.A. (N.S.) 944, note. Baker v. Libbie, supra, is probably the leading case in this country on the subject. In that case the Executor of Mary Eddy Baker, the founder of the Christian Science Movement, sued to restrain the publication of personal letters written by Mrs. Baker to a cousin about domestic and business affairs. The court in granting the injunction wrote a scholarly opinion in which it reviewed the authorities and re-examined the question on principle. The court concluded that: "The existence of a right in the author over his letters, even though private and without worth as literature, is established on principle and authority. The right is property in its essential features. It is, therefore, entitled to all the protection which the constitution and laws give to property." Relying principally on Baker v. Libbie, the Circuit Court of Appeals for the District of Columbia said in the fairly recent case of Hearst v. Black: "That there is and always has been a property right in letters and other writings which a court of equity will protect is too well settled to discuss. It is one of those rights which antedate the Constitution. It is inherent in a free government." The foregoing general rule rests entirely on the common law and does not appear to have been enacted into statute, at least not -2- |