Ackison v. Gergley

2025 Ohio 1112
CourtOhio Court of Appeals
DecidedMarch 28, 2025
Docket2024 CA 00036
StatusPublished

This text of 2025 Ohio 1112 (Ackison v. Gergley) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ackison v. Gergley, 2025 Ohio 1112 (Ohio Ct. App. 2025).

Opinion

[Cite as Ackison v. Gergley, 2025-Ohio-1112.]

COURT OF APPEALS LICKING COUNTY, OHIO FIFTH APPELLATE DISTRICT

MELISSA ACKISON : JUDGES: : Hon. Craig R. Baldwin, P.J. Plaintiff - Appellant : Hon. William B. Hoffman, J. : Hon. David M. Gormley, J. -vs- : : JOSEPH GERGLEY : Case No. 2024 CA 00036 : Defendant - Appellee : OPINION

CHARACTER OF PROCEEDING: Appeal from the Court of Common Pleas of Licking County, Case No. 2019 CV 1082

JUDGMENT: Affirmed

DATE OF JUDGMENT: March 28, 2025

APPEARANCES:

For Plaintiff-Appellant For Defendant-Appellee

J.C. Ratliff Thomas N. Spyker Nicholas A. Barons Mrinali Sethi 200 West Center Street 200 Civic Center Drive, Suite 800 Marion, Ohio 43302 Columbus, Ohio 43215 Gormley, J.

{¶1} This dispute — which involves the interesting interplay between the tort of

defamation and the First Amendment’s freedom-of-speech protection — is here for a

second time. Three years ago, our court overturned the trial court’s decision dismissing

a defamation claim, and we sent the case back for a new trial. That second trial has now

been held, and the case is here again. Because we conclude that the trial judge in the

second trial properly instructed the jury on the defamation claim at issue, and because

we also find that the jury’s verdict in favor of the defamation plaintiff was supported by the

weight of the evidence and that an award of attorney’s fees in his favor was proper, we

now affirm.

Facts and Procedural History

{¶2} This case was previously before this court on appeals from both parties.

See Ackison v. Gergley, 2022-Ohio-3490 (5th Dist.) (“Ackison 1”). At the time of the first

appeal, defendant Joseph Gergley owned and operated a small political consulting firm,

which specialized in public polling. In early 2018, plaintiff Melissa Ackison ran for a seat

in the U.S. Senate, and she hired Gergley to provide consulting services for that

campaign. Ackison lost a contested primary election in her race in May 2018. After her

campaign ended that year, Ackison and Gergley discussed working together on other

ventures. Their business relationship soured, however, in July or August of 2018, and

they did not work together after that time.

{¶3} In late 2019, Ackison filed a complaint against Gergley in Licking County,

and Gergley in turn filed a counterclaim against her. Gergley sought summary judgment

in his favor on Ackison’s claims against him, and the trial court granted that request. A jury trial was then held on Gergley’s counterclaim in which he alleged defamation,

defamation by innuendo, slander, slander per se, libel, libel per se, and false-light invasion

of privacy. At the close of Gergley’s case-in-chief, the trial court granted a directed verdict

in Ackison’s favor, finding that Gergley was a limited-purpose public figure and that he

had failed to prove that Ackison had acted with actual malice.

{¶4} On appeal, this court found that the trial court did not err in granting

summary judgment in favor of Gergley on Ackison’s complaint. This court also found,

however, that the trial court erred in viewing Gergley as a limited-purpose public figure.

We reversed the judgment, and we remanded the case for a new trial.

{¶5} A second jury trial on Gergley’s counterclaim was held in October 2023.

The jury in that trial ruled in favor of Gergley and awarded compensatory damages to him

of $25,000. Finding that Ackison acted with actual malice, the jury also concluded that

Ackison should pay punitive damages totaling $15,000. The jury determined, too, that

Ackison should pay Gergley’s attorney’s fees in the case.

{¶6} Following a hearing on Gergley’s application for attorney’s fees and

expenses, the trial court awarded attorney fees to him of roughly $85,000 as well as

expenses totaling more than $7,000. Ackison now appeals.

Gergley Was Properly Characterized as a Private Citizen Rather Than as a Limited- Purpose Public Figure

{¶7} Ackison contends first that Gergley ought to have been viewed as a limited-

purpose public figure in the second trial and that Gergley therefore should have been

required to prove actual malice on Ackison’s part in order for Gergley to recover any

damages on his defamation counterclaim. We disagree. {¶8} This was of course an issue that we addressed three years ago in the first

appeal. As we explained then, a limited-purpose public figure “is a person who becomes

a public figure for a specific range of issues by being drawn into or voluntarily injecting

himself into a specific public controversy” or by thrusting himself to the forefront of

particular public controversies “in order to influence the resolution of the issues involved.”

Ackison 1, 2022-Ohio-3490, at ¶ 61 (5th Dist.). And a “public controversy,” we explained,

“is a dispute that in fact has received public attention because its outcome will affect the

public or some segment of it in an appreciable way.” Id. at ¶ 62. Notably, too, a party

alleging that he or she has been harmed by allegedly defamatory statements does not

become a limited-purpose public figure simply by virtue of the fact that “the allegedly

defamatory statements create a controversy.” Id. Instead, “the controversy must have

existed prior to the statements.” Id.

{¶9} The statements by Ackison that Gergley claims were defamatory were

postings and comments about Gergley that Ackison placed on Twitter, Facebook, and

other social-media platforms. After examining the facts that had been presented during

the first trial, we concluded in the first appeal that in fact no “public controversy” existed

before Ackison posted her comments on the various online platforms. The comments

themselves certainly drew some public attention, but the absence of any prior public

controversy was fatal, we explained, to any argument by Ackison that Gergley was a

limited-purpose public figure when Ackison’s online postings appeared. Id. at ¶ 64.

{¶10} No evidence presented during the second trial causes us to change our

views about that issue. As in the first trial, no evidence in the record from the second trial points to any “public controversy” that existed before Ackison’s own statements about

Gergley drew some public attention.

{¶11} In our decision resolving the first appeal three years ago, we thoroughly

discussed the evidence presented during the first trial, and we marched through the key

First Amendment and defamation cases in which the concept of a limited-purpose public

figure has been addressed. We see no need to repeat that information here. Suffice to

say that the trial judge in the second trial saw no reason to second-guess our earlier

conclusion that Gergley was not a limited-purpose public figure when Ackison posted

online comments about him, and we likewise see no reason now to ourselves revisit that

conclusion.

{¶12} Ackison argues, however, that the public controversy here is not — as we

concluded in Ackison 1 — her social-media posts. She claims, instead, that the public

controversy at issue was her campaign for Ohio Senate that began in 2019 and continued

until April 2020 when she lost a primary election. She claims that Gergley involved himself

in that campaign by using his social-media presence to undermine her candidacy and

influence the outcome of the election. In her view, Gergley became a limited-purpose

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Eastley v. Volkman
2012 Ohio 2179 (Ohio Supreme Court, 2012)
Gilson v. Am. Inst. of Alternative Medicine
2016 Ohio 1324 (Ohio Court of Appeals, 2016)
Sweitzer v. Outlet Communications, Inc.
726 N.E.2d 1084 (Ohio Court of Appeals, 1999)
State v. Martin
485 N.E.2d 717 (Ohio Court of Appeals, 1983)
Talley v. Whio Tv-7
722 N.E.2d 103 (Ohio Court of Appeals, 1998)
Williams v. Gannett Satellite Information Network, Inc.
834 N.E.2d 397 (Ohio Court of Appeals, 2005)
Gosden v. Louis
687 N.E.2d 481 (Ohio Court of Appeals, 1996)
Sky v. Van Der Westhuizen
2019 Ohio 1960 (Ohio Court of Appeals, 2019)
Seasons Coal Co. v. City of Cleveland
461 N.E.2d 1273 (Ohio Supreme Court, 1984)
State v. Thompkins
678 N.E.2d 541 (Ohio Supreme Court, 1997)
McKimm v. Ohio Elections Commission
729 N.E.2d 364 (Ohio Supreme Court, 2000)
Ackison v. Gergley
2022 Ohio 3490 (Ohio Court of Appeals, 2022)
State v. Williams
2024 Ohio 5578 (Ohio Court of Appeals, 2024)
State v. Sheppard
2025 Ohio 161 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1112, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ackison-v-gergley-ohioctapp-2025.