How have courts interpreted privacy provisions in the past?

7 After "privacy" was explicitly added to our state Constitution in 1972, Porten v. University of San Francisco (1976) 64 Cal.App.3d 825, 134 Cal.Rptr. 839 perpetuated the cause of action. The Porten court did not discuss the question of how a constitutional provision can give rise to a right to damages except to briefly note, in passing, that the privacy provision was self-executing. (64 Cal.App.3d at p. 829, 134 Cal.Rptr. 839.)