Marion Manola (1865 – October 6, 1914) was a comic opera singer and actress. Widely popular on stage in the late 19th century, she transitioned to vaudeville in her later career. Newspapers of the time gave a great deal of attention to Manola's personal affairs, avidly documenting her relationships, activities, and illnesses. Manola divorced her first husband to marry popular actor John B. Mason, with whom she frequently performed. Their marriage was marked by illnesses, financial difficulties, substance abuse, and allegations of adultery. After their divorce, she continued to perform sporadically.
Manola famously objected to a surreptitious photograph taken of her on stage in tights. Her successful lawsuit against the photographer is cited in the influential law review article, "The Right to Privacy".
Early life and career
Marion Stephens was born in Oswego, New York, in 1865. She grew up in Cleveland, where she enjoyed participating in local amateur operas. When she was 17 years old, she married Henry C. Mould, a local businessman. Their daughter, Adelaide, was born soon after.
After Mould experienced some business difficulties, the family moved to Europe. Marion, a soprano whose ambition was to sing grand opera, studied in Paris with Mathilde Marchesi for nine months. The couple then moved to England and joined the Lingard and Van Biene's comic opera company. Mould took the stage name of Carl Irving and Marion became Marion Manola. Manola and Irving appeared together in Falka, and they both received positive reviews. Manola was offered a five-year contract with the company, but she turned it down to return to the United States with Mould in 1887. Manola and Irving started at the Casino Theatre in New York. Her initial American performances received poor reviews, so Manola offered the company her resignation and was stunned to have it accepted. She then joined McCaull Opera Company, appearing as Cérise in Erminie. In 1887, she starred as Countess Ulla in Franz von Suppé's comic opera Bellman.
Mould retired from acting in 1888, going into business in the iron industry. In April 1889, Manola filed for legal separation from Mould and requested custody of their daughter. The McCaull company manager said the grounds for the suit was non-support. A friend of Mould's attributed their problems to Manola being hired by the McCaull company while Mould was not, and said Mould would not be willing to give up custody of Adelaide.
During the summer of 1889, Manola appeared in the opera Clover, achieving conspicuous success. The Pittsburgh Dispatch called Manola "the best comic opera prima donna in America". At a time when working girls might earn between $4 and $10 a week, Manola was paid $400 a week. Manola had a reputation for being temperamental. In one incident, she claimed a fellow actor had pushed her on stage, and Manola refused to perform with him again until he apologized.
Manola contracted to appear with the De Wolf Hopper Opera Bouffe Company in 1890, attempting to quit the McCaull Company before her contract with it expired. When she claimed to be ill, McCaull was granted an injunction against Manola to prevent her from singing with any other company until the McCaull contract expired.
Photographed in tights
During a June 14, 1890, performance of the comic opera Castle in the Sky, a photographer surreptitiously took a picture of Manola. She angrily left the stage, while the audience booed at the trick played upon her. Manola explained her objection in an interview:
The company manager, Benjamin Stevens, claimed Manola had been photographed in tights several years earlier while working for him in the McCaull company; the manager also argued that there was no difference between performing in tights and being photographed in tights.
Stevens had engineered the photograph stunt for the publicity that it would bring. In Manola v. Stevens, Manola was granted an interim injunction which restrained the company and the company manager from using her photograph. Manola's case, cited in the 1890 Harvard Law Review article, "The Right to Privacy", by Samuel Warren and Louis Brandeis, was one of the first to assert that an actress had a property right in her own professional image.