In Baker v. Burlington N., Inc., 99 Idaho 688, 587 P.2d 829 (1978), the plaintiff alleged that his right to privacy was violated by his employer's disclosure of his previous criminal record. The defendant railroad discharged Baker after it discovered that he had a criminal record, contrary to the information he had provided on his employment application. The letter of discharge was forwarded to a number of individuals, including management personnel at the railroad, the Idaho Department of Employment, and Baker's union. The Idaho Supreme Court held that the disclosure was not actionable as an invasion of privacy because the publication "was merely a recitation of a public record of Baker's recent criminal activity." 99 Idaho at 692, 587 P.2d at 833.