"The paparazzo is just as much covered by the First Amendment as you or I, or any Joe Schmo up the street," said Lucy Dalglish, executive director of the Virginia-based Reporters Committee for Freedom of the Press.

"I don't think under any First Amendment law you can single out a paparazzi photographer."

But concerns over public safety are making city leaders contemplate measures to restrict how paparazzi can operate -- Malibu is the latest area to propose legislation.

"My obligation is to protect everyone, not just the paparazzi," said Councilman Andy Stern, representing Malibu City .

"If they want us to ignore them, that's just not going to happen."

Earlier this year in nearby Los Angeles, a law proposed that paparazzi should stay several feet away from the stars that they photograph.

"It's becoming more combative where people are saying they've had enough with these people," said LA Councilman Dennis Zine.

"Right now, you have no laws that really apply."

"You have a chaotic situation that keeps on getting worse."

The number of paparazzi increase every year, driven by falling equipment costs and the growing desire of the public to see celebrities at their most vulnerable.

"They want to see them with their hair kind of messed up, they want to see them with maybe some spaghetti sauce on their shirt, they want to see them a little bit pudgy," said Brad Elterman, co-owner of Los Angeles-based agency Buzz Foto.

Elterman pointed out that one good shot could be sold to multiple outlets, making the business a lucrative way to make money without excessive effort.

"It's like the Mafia, once you're in you never want to leave," he said.