in the courts, the invasion of the right of privacy has been a complex of four distinct wrongs, whose only relation to one another is that each involves interference with the interest of the individual in leading, to some reasonable extent, a secluded and private life ***.” Id. cmt. b, at 377. Relevant here is the tort of public disclosure of private facts. Id. § 652D. To state a cause of action, the plaintiff must prove that (1) the defendant gave publicity (2) to the plaintiff’s private and not public life (3) and that the matter made public was highly offensive and (4) not of legitimate public concern. Doe v. TCF Bank Illinois, FSB, 302 Ill. App. 3d 839, 841 (1999); see Restatement (Second) of Torts § 652D cmt. d (1977); Prosser and Keeton on the Law of Torts § 117, at 856-57 (W. Page Keeton et al. eds., 5th ed. 1984). With their longstanding historical pedigree, invasion of privacy torts broadly developed across the country, without any established first amendment limitations, to protect the privacy of nonpublic figures with respect to matters of only private interest. See VanBuren, 2018 VT 95, ¶ 43. Thus, section 11-23.5 is distinguishable from the law prohibiting depictions of animal cruelty that the Supreme Court struck down in Stevens, 559 U.S. at 469 (stating that the Court was “unaware of any similar tradition excluding depictions of animal cruelty from ‘the freedom of speech’ codified in the First Amendment” (emphasis omitted)). ¶ 64 Indeed, we observe that the United States Supreme Court has never declared unconstitutional a restriction of speech on purely private matters that protected an individual who is not a public figure for an invasion of privacy. Rather, the Supreme Court has repeatedly reconciled the tension between the right to privacy and free speech by analyzing the specific privacy claim and the public interest in the communication in each case. See, e.g., Time, Inc. v. Hill, 385 U.S. 374, 383 n.7 (1967) (declining to announce categorical rule on whether truthful publication of revelations so intimate as to shock community’s notions of decency could be constitutionally proscribed); Cox Broadcasting Corp. v. Cohn, 420 U.S. 469, 491 (1975) (same); Florida Star v. B.J.F., 491 U.S. 524, 532-33 (1989) (same); Bartnicki, 532 U.S. at 529 (same). ¶ 65 These Supreme Court decisions reflect three consistent themes. First, speech on matters of private concern that invades the privacy interests of nonpublic figures does not enjoy the same degree of first amendment protection as speech on matters of public concern or relating to public figures. Second, state laws protecting individual privacy rights are long established and are not necessarily subordinate to - 19 -