In Operating Engineers Local 3 v. Johnson (2003) 110 Cal.App.4th 180, the court concluded an invasion of the constitutional right of privacy "by definition necessarily involves conduct that goes beyond 'broadly based and widely accepted community norms' of acceptable employer conduct." In that case, a jury found an employer violated the plaintiff's right to privacy by announcing in a meeting in the presence of other employees the plaintiff would be reprimanded, directing her to write her own letter of reprimand and then distributing the minutes publishing the reprimand to additional employees. (Id. at p. 184.) The appellate court concluded the plaintiff's claims were not barred by the exclusive remedy doctrine because the conduct "violated a right conferred by the California Constitution and thus was contrary to a fundamental public policy. The violation of such a clearly articulated public policy reinforces the basis for holding defendants' conduct to exceed what may be considered normal employer behavior within the compensation bargain." (Id. at p. 190.)