To determine the treatment of visual journalism by privacy law from the origins of privacy law in 1890 until 1978, an analysis was made of the mass media legal cases occurring between those years. The cases were subjectively divided into three categories: those that established or extended a freedom of the press or the right of a defendant to gather, store, or disseminate information; those that limited or narrowed the right of the press or defendant to gather, store, or disseminate information; and those cases that did not relate to the question or were neutral. The cases were then coded for visual content: sketches, photographs, newsreels, cartoons, nonadvertising posters, documentary movies, and television news and documentaries. The analysis supported the statements that privacy law grew out of a response to visual journalism and that the law of privacy as it affects journalism is primarily visual. In addition, the privacy law was more restrictive of visual than of print journalism. Over 80% of all restricting privacy cases pertained to visual journalism. The results suggest that a lack of distinction between the forms (channels) of the invasion of privacy has obscured its historical origins and made the law of privacy more murky and more restrictive. (HOD)