Assuming you mean in the United Stares, can you cite a specific law or court case to support your position?
It occurs to me that the existence of paparazzi seems to be evidence against your position.
Paparazzi get sued for crossing lines all the time. Good ones know exactly how far they can push the boundary and are careful to stay close to it
Not federal, but this: https://codes.findlaw.com/ca/civil-code/civ-sect-3344/ To be clear by 'commercial purposes', it's advertising/promotion/marketing. Paparazzi photos would be alright by that bar. I presume the idea is to avoid any implied endorsement by those photographed.