American v. Hayhurst

2000 DNH 205
CourtDistrict Court, D. New Hampshire
DecidedSeptember 29, 2000
DocketCV-98-126-M
StatusPublished
Cited by1 cases

This text of 2000 DNH 205 (American v. Hayhurst) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American v. Hayhurst, 2000 DNH 205 (D.N.H. 2000).

Opinion

American v . Hayhurst CV-98-126-M 09/29/00 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

American Association of Naturopathic Physicians, Plaintiff

v. Civil N o . 98-126-M Opinion N o . 2000 DNH 205 Donald Hayhurst and American Naturopathic Medical Association, Inc., Defendants

O R D E R

Plaintiff, American Association of Naturopathic Physicians

(“AANP”), brings this diversity action against Defendants Donald

Hayhurst and the American Naturopathic Medical Association, Inc.

In its two count complaint, AANP sets forth the bases for its

claimed entitlement to damages for malicious prosecution and

conspiracy.1 Hayhurst moves for summary judgment.

1 Periodically, AANP’s pleadings make reference to a claim for abuse of process - one that AANP apparently views as being independent of its claim for malicious prosecution. The “corrected version” of its amended complaint (document n o . 88) sets forth no such independent claim, however. Standard of Review

When ruling upon a party’s motion for summary judgment, the

court must “view the entire record in the light most hospitable

to the party opposing summary judgment, indulging all reasonable

inferences in that party’s favor.” Griggs-Ryan v . Smith, 904

F.2d 1 1 2 , 115 (1st Cir. 1990). Summary judgment is appropriate

when the record reveals “no genuine issue as to any material fact

and . . . the moving party is entitled to a judgment as a matter

of law.” Fed. R. Civ. P. 56(c). In this context, “a fact is

‘material’ if it potentially affects the outcome of the suit and

a dispute over it is ‘genuine’ if the parties’ positions on the

issue are supported by conflicting evidence.” Intern’l Ass’n of

Machinists and Aerospace Workers v . Winship Green Nursing Center,

103 F.3d 196, 199-200 (1st Cir. 1996) (citations omitted).

Background

This case represents yet another battle in an enduring feud

between the parties. The struggle began in various state

legislative arenas over whether legislation should be enacted to

provide for the licensing of naturopathic physicians. It has, at

2 times, been quite heated and even venomous, as each side has

attempted to discredit the other in the eyes of legislators and

state policy-makers. As it progressed, the feud seems to have

“matured” from a political debate as to which reasonable minds

might certainly differ, into mere ad hominem exchanges fueled by

increasing personal acrimony on both sides. Unfortunately, the

dispute has spilled over into the judicial forum.

During the course of AANP’s political lobbying relative to

the licensing issue, it (and persons acting on its behalf)

distributed materials critical of Hayhurst’s education and

professional credentials, in an obviously calculated effort to

demean him and undermine his political credibility. Those

materials sometimes included an article highly critical of

Hayhurst published in the April 1990 issue of Townsend Letter for

Doctors (an article that was subsequently retracted by the

publisher, who also offered an apology to Hayhurst for any

“embarrassment, hurt, and inconvenience this article caused D r .

Hayhurst.”). See Exhibit 15 to Affidavit of Donald Hayhurst,

Townsend Letter for Doctors (August/September, 1992), at 746.

3 Notwithstanding that retraction and apology, it appears that AANP

and/or its agents continued to circulate the original article.

In response, Hayhurst brought twelve separate lawsuits in

various federal district courts (including this o n e ) , in which he

alleged that the statements being issued and the materials being

circulated by AANP in those fora defamed him. AANP says that two

of those cases settled (though the record suggests that at least

four were settled by the so-called “Weeks” release) and three

were either dismissed on the pleadings or were resolved by

summary judgment against Hayhurst, including the proceeding filed

in this court. See AANP’s objection to summary judgment

(document n o . 68) at 2-3. The status (or outcome) of the

remaining suits is unclear.

AANP now presses this two count action against Hayhurst,

alleging (1) malicious prosecution in the institution and

maintenance of the referenced suits and (2) a civil conspiracy

between Hayhurst and the American Naturopathic Medical

Association involving their alleged pursuit of a course of

4 conduct, including the bringing and maintenance of the referenced

suits, and designed to destroy AANP. Although AANP says it seeks

compensation for Hayhurst’s allegedly wrongful conduct in

numerous judicial fora, the evidence it has presented in

opposition to the motion for summary judgment relates almost

exclusively to the defamation action Hayhurst brought in this

court.

As discussed more fully below, neither AANP’s malicious

prosecution nor its conspiracy claim has sufficient support in

the record evidence to survive Hayhurst’s motion for summary

judgment.

Discussion

I. Count 1 - Malicious Prosecution.

Under New Hampshire law, a “successful action for malicious

prosecution requires proof that the plaintiff was subjected to a

civil proceeding instituted by the defendant, without probable

cause and with malice, and that the proceedings terminated in the

plaintiff’s favor.” ERG, Inc. v . Barnes, 137 N.H. 186, 190

5 (1993) (citations omitted). Hayhurst argues that AANP cannot

establish the third and fourth elements of the cause of action

(i.e., lack of probable cause and the existence of malice).

A. Probable Cause.

The existence of probable cause is ultimately a question of

law for the court. Of course, when it turns upon the resolution

of factual disputes or the credibility of witnesses, the

existence of probable cause becomes a mixed question of law and

fact. See Stock v . Byers, 120 N.H. 8 4 4 , 846 (1980); MacRae v .

Brant, 108 N.H. 1 7 7 , 180 (1967). Here, however, AANP has

identified no such material factual disputes. S o , whether

Hayhurst had probable cause to file the New Hampshire defamation

action can be resolved as a matter of law.

To establish a lack of probable cause “[t]he plaintiff [i]s

required to prove that the defendants, when they brought their

suits against him, did not possess such knowledge of facts ‘as

would lead a man of ordinary caution and prudence to believe’

that they had a cause of action against the plaintiff.” Cohn v .

6 Saidel, 71 N.H. 5 5 8 , 567 (1902) (citation omitted). See also

Aranson v . Schroeder, 140 N.H. 359, 367 (1995) (holding that a

litigant acts without probable cause when he or she acts “without

any credible basis in fact and such action is not warranted by

existing law or established equitable principles or a good faith

argument for the extension, modification, or reversal of existing

law.”). Thus, the burden imposed on a defendant in a proceeding

for malicious prosecution - to demonstrate probable cause to

initiate the underlying civil action in which he or she was the

plaintiff - is not especially onerous.

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