ts to the general manager of the center. Kmart assigned one investigator to focus on theft, sabotage, safety, and drug use. A second investigator was also asked to report any evidence of theft or drug use.
             The trial court granted Kmart's motion for summary judgment on the employees' invasion of privacy claim, finding that there was no unauthorized intrusion because the employees voluntarily disclosed their personal information in conversations with the investigator-employees. Although a voluntary disclosure of private information will normally defeat a claim for invasion of privacy2, the Illinois appellate court reversed the trial court, finding that the conversations were not truly voluntary because they were induced by deceptive means3. Accordingly, the court found that the employees had a reasonable expectation of privacy in their conversations with co-workers, and it was a question of fact as to whether the unauthorized intrusion into matters relating to their private lives would be offensive or objectionable to a reasonable person4.
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