<P> Other states (and the District of Columbia) not listed above require only that one party consent to the recording . </P> <P> Following the Illinois Supreme Court's decision in People v. Clark on March 20, 2014, which struck down Illinois' two - party consent law, Illinois was a one - party consent state . However, the state legislature amended the statute and, as of December 30, 2014, Illinois is once again a two - party consent state, although the revised law establishes a one - party consent rule for private electronic communications . </P> <P> The Michigan Court of Appeals ruled in 1982 that participants in a conversation may record a discussion without getting the permission of other participants . The ruling stated that eavesdropping only applies to: "a third party not otherwise involved in the conversation being eavesdropped on". This is because the law uses the wording, "the private discourse of others", rather than the wording, "the private discourse of others or with others". Michigan law is often misinterpreted as requiring the consent of all parties to a conversation . </P> <P> The California Supreme Court ruled in 2006 that if a caller in a one - party state records a conversation with someone in California, that one - party state caller is subject to the stricter of the laws and must have consent from all callers (cf . Kearney v. Salomon Smith Barney Inc., 39 Cal . 4th 95). However, non-disclosure recordings by one of the parties can legally be made if the other party is threatening kidnapping, extortion, bribery, human trafficking, or other felony violence . Also included in the exception is misdemeanor obscenity and threats of injury to persons or property via an electronic communication device (usually a telephone) if directed in whole or in part towards a conversation participant or family members . </P>

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