Libel per quod is simply libel that is not actionable per se. ERISA In D Magazine Partners we said that the supreme court's 2000 Turner opinion suggests that lack of privilege might be an element of a defamation plaintiff's case, while its 2013 Neely opinion indicates that privilege is a defense. 5. On that occasion, he said, he attempted to contact the author of one of the obituaries. Is there evidence that the column's gist was false? Appellees' contrary argument fails on the first prong we referenced abovethe existence of a public controversy for the Tatums to participate in. This meaning is defamatory because it tends to injure the Tatums' reputations and to expose them to public hatred, contempt, or ridicule. In that regard, the statement must point to the plaintiff and to no one else. Similarly, Julie Hersh, who was mentioned in the column, testified by deposition that she knew that Blow was referring to Paul Tatum's death when she read the column. Even if the statements in a publication are not defamatory when taken individually, a publication can be defamatory if it creates a defamatory impression by omitting material facts or juxtaposing facts in a misleading way. The Dallas Express a newspaper printed by and for the city's African American community ALSO essential sadly, only the years 1919-1924 have been scanned, here The Jewish Monitor published in Fort Worth, serving the DFW (and Texas) Jewish community, 1919-1921, here The Texas Jewish Post, 1950-2011, here Waste Mgmt. See Tex.R. Id. Like a cat putting its nose to the wind, that curiosity is part of how we gauge the danger out there for ourselves and our loved ones. dallas morning news v tatum oyezitalian catering delray beach. of Tex., Inc. v. Tex. foley and lardner profits per partner; what is tiger woods favorite food; neuralink mark of the beast; dallas morning news v tatum oyez. 73.001. Austin v. Inet Techs., Inc., 118 S.W.3d 491, 496 (Tex.App.Dallas 2003, no pet.). Did the Tatums raise a genuine fact issue regarding whether the column was about them? Gacek v. Owens & Minor Distrib., Inc., 666 F.3d 1142, 114748 (8th Cir.2012); Scholz v. Bos. See Neely, 418 S.W.3d at 62; Bentley, 94 S.W.3d at 57985. We reject the Tatums' second appellate issue. Again, a statement is defamatory if it tends to (i) injure the subject's reputation, (ii) expose him to public hatred, contempt, ridicule, or financial injury, or (iii) impeach his honesty, integrity, or virtue. Prac. We conclude that there was more than a scintilla of evidence showing more than a mere failure to conduct a reasonable investigation. See id. pending). Please try again. Although there is evidence that people in Paul's high school community were discussing his death generally, and that unspecified others in north Dallas were also discussing it before the column was published, there is no evidence that the cause or manner of Paul's death affected anyone other than the Tatums. The Tatums' DTPA claims are based on 17.46(b)(24) of the DTPA, which provides that it is a false, misleading, or deceptive act or practice to fail [] to disclose information concerning goods or services which was known at the time of the transaction if such failure to disclose such information was intended to induce the consumer into a transaction into which the consumer would not have entered had the information been disclosed. Tex. Bus. See Neely, 418 S.W.3d at 63. In their second appellate issue, the Tatums contend that the trial court erred by granting summary judgment on their DTPA claims against DMN. The Tatums timely filed a second notice of appeal. Accordingly, because there is no evidence of a public controversy that could make the Tatums limited-purpose public figures, we conclude that the Tatums are private figures for purposes of this summary judgment appeal. Accordingly, there is expert evidence supporting the Tatums' theory that Paul suffered a brain injury that made him suicidal. Because these privileges are affirmative defenses, see Denton Publ'g Co. v. Boyd, 460 S.W.2d 881, 882, 885 (Tex.1970) (interpreting predecessor statute to 73.002), appellees' summary judgment motion had to conclusively prove their elements to prevail.6. There was also evidence that Blow did not adhere to his usual practice of investigation when he wrote the column. But it's such a missed opportunity to educate.. See D Magazine Partners, L.P. v. Rosenthal, No. In this context, negligence has two prongs: (1) the publisher knew or should have known that the defamatory statement was false, and (2) the factual misstatement's content was such that it would warn a reasonably prudent editor or broadcaster of its defamatory potential. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, Stay up-to-date with FindLaw's newsletter for legal professionals. There was a page break in the middle of the column, and a slightly different headline appeared over the remainder of the column when it resumed on another page: Shrouding suicide in secrecy leaves its danger unaddressed. The column, with emphasis added, stated as follows: So I guess we're down to just one form of death still considered worthy of deception. The column was true or substantially true. Am. There was no evidence of actual malice. One was an email to Blow in which the author wrote, He [Paul] was a popular and accomplished young man and many people understood to whom you referred.. %%EOF Stay up-to-date with how the law affects your life. Posted By : / chsaa basketball rule book /; Under :international cultureinternational culture Did you know that almost twice as many people die each year from suicide as from homicide? Bankruptcy In cases not covered by these mandates, Texas has generally made truth an affirmative defense to defamation. More than 1,000 people attended Paul's funeral. Construction Law A statement does not have to refer to the plaintiff by name, however, if people who know and are acquainted with the plaintiff reasonably understand from reading the statement that it referred to the plaintiff. Main, 348 S.W.3d at 395; see also Houseman v. Publicaciones Paso del Norte, S.A., 242 S.W.3d 518, 525 (Tex.App.El Paso 2007, no pet.) Sympathy Ideas. 0 Constr., L.P. v. Underwriters at Lloyd's London, 327 S.W.3d 118, 127 (Tex.2010) (citing dictionaries as aids to interpreting an insurance policy). Id. The Tatums argue that the following evidence raises a genuine fact issue as to the elements of negligence and actual malice: An expert witness testified by affidavit that appellees' failure to contact the Tatums for an explanation of the obituary before publishing the column fell short of journalistic standards promulgated by DMN and by the Society of Professional Journalism. WFAATV, Inc. v. McLemore, 978 S.W.2d 568, 571 (Tex.1998). Heritage Capital, 436 S.W.3d at 875; Main v. Royall, 348 S.W.3d 381, 389 (Tex.App.Dallas 2011, no pet.). We agree with the Tatums. Issue One: Did the trial court err by dismissing the Tatums' libel claims? Prac. The summary judgment evidence conflicts on certain points regarding the newspaper's investigation into Paul's death and the manner in which Blow learned about the immediate cause of Paul's death. In adopting the verifiable as false test in Bentley and Neely, the Texas Supreme Court relied on the United States Supreme Court's decision in Milkovich v. Lorain Journal Co., 497 U.S. 1 (1990). Id. That appeal is also being decided today, John Tatum and Mary Ann Tatum v. Julie Hersh, No. The Tatums submitted evidence showing that: One, their motive in stating that Paul died as a result of injuries sustained in an automobile accident was to express their belief, after investigation, that the best explanation of the underlying cause of Paul's suicide was a brain injury sustained in the auto accident. Turner, 38 S.W.3d at 114. Landfill, Inc., 434 S.W.3d 142, 15657 (Tex.2014) (citing Gertz v. Robert Welch, Inc., 418 U.S. 323, 349 (1974)). But a topic is not a public controversy merely because some people are talking about it: A general concern or interest will not suffice. See Hancock v. Variyam, 400 S.W.3d 59, 64 (Tex.2013) (Defamation per quod is defamation that is not actionable per se.). This opinion should not be construed to hold that the column necessarily defamed the Tatums. Public Benefits Prac. See Deception, Webster's Third New International Dictionary of the English Language Unabridged (1981) (the act of deceiving, cheating, hoodwinking, misleading, or deluding); see also Deceive, id. Supreme Court of Texas. Newspapers, Inc. v. Hepps, 475 U.S. 767 (1986). Suicide is the third-leading cause of death among young people (ages 15 to 24) in this country. Two, they did not mention suicide in the obituary because (i) they believed it would give a false impression that Paul committed suicide as a result of depression or other mental illness and (ii) they did not feel it would honor Paul's memory to include morbid details about his death or to include overly scientific information. But the Tatums must prove actual malice to recover exemplary damages if the defamatory statement involved a matter of public concern (as opposed to a public controversy) and appellees are media defendants. dallas morning news v tatum oyezsims 4 university homework cheat. In this context, actual malice means knowledge of, or reckless disregard for, the falsity of a statement. Id. Herald, Inc., No. 3. Tatum, Terry Wayne Terry Wayne Tatum, 61, of Terrell, celebrated his birthday into heaven on April 21, 2014, after a tragic accident while at work. Unlike the current trend of local news being acquired by private equity firms and national chains, we have been a family-controlled company for over 135 years. 3. 17.50(a)(1)(A)(B). For this privilege to apply, however, the law requires that the comment at issue purported to be, and was, only a fair, true and impartial report of what was stated at the meeting, regardless of whether the facts under discussion at such meeting were in fact true, unless the report was made with malice. Denton Publ'g Co., 460 S.W.2d at 883. We're nearly obsessed with crime. Argued January 10, 2018. The above parts alone could cause a person of ordinary intelligence to read the column as accusing the Tatums of deceit by writing an obituary that stated a false cause of Paul's death and concealed the true cause of his death (for their own self-benefit and to the detriment of society as a whole). Limited-purpose public figures are generally people who have thrust themselves to the forefront of a particular public controversy to influence its resolution, or who have voluntarily injected themselves or been drawn into a public controversy. We recently cited Lipsky and placed the burden of proving falsity on the plaintiff in a libel case involving the Texas Citizens Participation Act, Civ. V. THE DALLAS MORNING NEWS, INC. AND STEVE BLOW, Appellees . Obituaries Section. ", "We are sorry for the Tatum family's tragic loss of their son," said Mike Wilson, editor of The News. of Tex., Inc., 434 S.W.3d at 15657. In that case, Dr. Neely was disciplined for self-prescribing medications, but a news broadcast about him could reasonably have been understood to report that he was actually disciplined for operating on patients while using dangerous drugs or controlled substances. at 6667. People who were familiar with the situation understood the column to refer to Paul and his parents. O. Texas Supreme Court dismisses defamation lawsuit against The Dallas Morning News John and Mary Ann Tatum, whose 17-year-old son shot himself, sued The News in 2011 alleging that a. Election Law The column, captioned Shrouding suicide leaves its danger unaddressed, criticized people who are dishonest about loved ones' suicides. Appellees, however, counter that no ordinary reader would think the column defames the Tatums. Tax Law On Monday, May 17, 2010, the Tatums were out of town at another son's graduation, and Paul was home alone. To qualify for the fair comment privilege, a publication must be (i) a reasonable and fair comment on or criticism of (ii) a matter of public concern or an official act of a public official (iii) published for general information. 17.46(b)(24); see also Brennan v. Manning, No. We reverse the trial court's summary judgment to the extent it orders the Tatums to take nothing on their libel and libel per se claims. denied). In this libel-by-implication case, a column written by Steve Blow and published by The Dallas Morning News (collectively, Petitioners) was reasonably capable of meaning that John and Mary Ann Tatum ac. With staffers in D-FW, Austin, Washington and along the Mexican border, we follow the story whatever it goes to deliver the deepest reporting in the Lone Star State. And the secrecy surrounding suicide leaves us greatly underestimating the danger there. Copyright 2023, Thomson Reuters. Utilities Law The next seven paragraphs describe two recent occurrences meant to illustrate Blow's pointthe events surrounding the deaths of Ted Pillsbury and Paul Tatum. Nonetheless, the Tatums filed affidavits by two experts. For the reasons discussed below, we conclude that their cases are distinguishable or otherwise unpersuasive. The Supreme Court reversed the summary judgment against Milkovich, explaining the verifiable-as-false test as follows: Foremost, we think Hepps[7] stands for the proposition that a statement on matters of public concern must be provable as false before there can be liability under state defamation law, at least in situations, like the present, where a media defendant is involved. Subscribe https://t.co/MqPw2ZUctn But what was apparent to every witness on the scene that day was that Pillsbury had walked a few paces from his car and shot himself. More recently, a paid obituary in this newspaper reported that a popular local high school student died as a result of injuries sustained in an automobile accident.. You can explore additional available newsletters here. We are unpersuaded by appellees' contrary arguments. 2. May 11, 2018. Corporate Compliance at 47. Nevertheless, the Milkovich Court concluded that calling someone a liar and accusing someone of perjury are both sufficiently verifiable to support a defamation claim. The case of Laird v. Tatum raised questions about the use of surveillance by the military and how it might affect the First. 73.001. The trial court granted Defendant's motion to dismiss Plaintiffs' action under the Texas Citizens Participation Act. A three-judge district court agreed with the challengers that the map likely violated Section 2 of the VRA, granting a preliminary injunction that ordered the state to draw a new map. See Neely, 418 S.W.3d at 72. There was a car crash, all right, but death came from a self-inflicted gunshot wound [page break] in a time of remorse afterward. 16-0098 Supreme Court of Texas May 11, 2018. 16-0098 THE DALLAS MORNING NEWS, INC. AND STEVE BLOW, PETITIONERS v. JOHN TATUM AND MARY ANN TATUM, RESPONDENTS ON PETITION FOR REVIEW FROM THE COURT OF APPEALS FOR THE FIFTH DISTRICT OF TEXAS Argued January 10, 2018 JUSTICE BROWN delivered the unanimous opinion of the Court with respect to Parts I, II, We resolved that case, however, without deciding the issue because the placement of the burden there would not have affected the outcome.Although Turner contains a passing remark in dicta that a defamation plaintiff must prove that the publication is not privileged, 38 S.W.3d at 115, it does not cite Denton Publishing Co. or hint that it overrules that case's holding that privilege is an affirmative defense, 460 S.W.2d at 885. For the reasons discussed below, we conclude that they did. They also argue that the description of Paul as popular is inconsistent with an imputation of mental illness, as is the assertion that he committed suicide in a time of remorse after a car crash. But the court went on to hold that "to the extent that the column states that the Tatums acted deceptively, it is true." Accordingly, neither a traditional nor a no-evidence summary judgment could properly be granted against the Tatums on the theory that the column was not about them. The column's headline was Shrouding suicide leaves its danger unaddressed. (Emphasis added). Daily resource for best restaurants in Dallas, recommendations for things to do, local news and commentary on life in Dallas. No. Plaintiffs sued Defendant for intentional infliction of emotional distress (IIED), claiming that Defendant exploited the tragedy of their son's death by encouraging the criticism of their son's obituary. The Tatums' friend Lee Simpson testified by affidavit that he was contacted by Tomaso about Paul's death and that Tomaso did not ask him whether the Tatum family wanted to be contacted. Our work has been recognized with nine Pulitzer Priz Location & Hours 1954 Commerce St Dallas, TX 75201 We long ago stated that it is the settled law of Texas, that a false statement of fact concerning a public officer, even if made in a discussion of matters of public concern, is not privileged as fair comment.. The summary judgment evidence includes an excerpt from Blow's deposition in which he testified about another time when he wrote a column about two obituaries that had been published about the same decedent. Id. But, here he did not attempt to contact the Tatums before publishing the column at issue in this case. We draw this factual recitation from the allegations in the Tatums' live petition: The Tatums were Paul Tatum's parents. See McConnell v. Southside Indep. The test here is whether the defamatory statement is verifiable as false. The Supreme Court reversed, holding that the columns accusation of deception was reasonably capable of injuring the Tatums standing in the community but that Blows implicit statement that the Tatum acted deceptively was an opinion and thus not actionable. On appeal, appellees argue only that the affidavits are too speculative. Appellees won a take-nothing summary judgment. Id. DMN also asserted the following no-evidence grounds: There was no evidence that the Tatums were consumers. Copyright Blow's controversial practice of attacking obituaries. In their affidavits, both Tatums said that they would not have published the obituary as worded if they had known that DMN had someone on staff who had a history of criticizing obituaries like Steve Blow.. Although appellees contend that the column's gist does not include any comment on the Tatums' character or their actions, we disagree. We are not persuaded. Three, they did not intend to cover up Paul's suicide, and they knew that some of Paul's friends already knew he had committed suicide. One expert explained the severity of Paul's auto accident, and the other opined that Paul committed suicide because of a brain injury sustained in that accident. In our analysis of this question, we focus on DMN's second no-evidence ground and particularly the first requirement of 17.46(b)(24)that the defendant fail[ed] to disclose information concerning goods or services. Id. The Tatums sued Julie Hersh in a separate lawsuit. We therefore do not address whether those categories apply here. Entertainment & Sports Law This is some evidence of actual malice. The Tatums timely responded. When one of my colleagues began to inquire, thinking the death deserved news coverage, it turned out to have been a suicide. They also sued DMN for DTPA violations. New York Times v. Sullivan-Alabama city commissioner sued NY Times -said an ad they published describing mistreatment of African American students had defamed him by implication-some of the statements in the ad were false or exaggerated, but those were small details Become a business insider with the latest news. We affirm the judgment to the extent it orders the Tatums to take nothing on their DTPA claims. There is thus some evidence from which a reasonable factfinder could find negligence's first prongthat appellees should have known of the defamatory statement's falsity, but failed to use reasonable care to ascertain the truth of the column's gist. Thus, there is evidence that Blow did not investigate this column with the same thoroughness that he did for a previous column and that his explanation for the difference was not true. Additionally, the summary judgment evidence established that the Tatums were out of town the day the column was published. 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