Andrew HaLevi PHD v. Charleston County School

CourtCourt of Appeals of South Carolina
DecidedJanuary 31, 2024
Docket2020-001460
StatusUnpublished

This text of Andrew HaLevi PHD v. Charleston County School (Andrew HaLevi PHD v. Charleston County School) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Andrew HaLevi PHD v. Charleston County School, (S.C. Ct. App. 2024).

Opinion

THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA In The Court of Appeals

Andrew HaLevi, Ph. D., Appellant,

v.

Charleston County School District, Respondent.

Appellate Case No. 2020-001460

Appeal From Charleston County Bentley Price, Circuit Court Judge

Unpublished Opinion No. 2024-UP-041 Submitted October 2, 2023 – Filed January 31, 2024

AFFIRMED

Lucy Clark Sanders and Nancy Bloodgood, both of Bloodgood & Sanders, LLC, of Mt. Pleasant, for Appellant.

Eugene Hamilton Matthews, of Richardson Plowden & Robinson, PA, of Columbia, for Respondent.

PER CURIAM: Andrew HaLevi (Dr. HaLevi) appeals the circuit court's grant of summary judgment to Charleston County School District (the District) on his claims of defamation, violation of due process, and breach of the covenant of good faith and fair dealing. We affirm summary judgment. FACTS/PROCEDURAL HISTORY

In 2009, the District hired Dr. HaLevi for the position of "Program Coordinator" at Septima Clark Academy (Clark Academy). The District classified the job as an "Assistant Principal Level 3 Grade 13 Step 16." On April 12, 2016, the District sent Dr. HaLevi a letter wherein it characterized his position at Clark Academy as "Associate Principal."

In April 2016, a female Clark Academy student violated the dress code, and Dr. HaLevi's actions regarding the incident attracted public attention. The student sued Dr. HaLevi and the District. Dr. HaLevi was placed on administrative leave, and the Post and Courier newspaper published an article titled "Clark Academy Principal Placed on Leave." Another article in The Chronicle quoted "county school board member" Chris Collins as saying "I think [Dr. HaLevi] just got mad . . . I think he should be fired, but I don't think there is board support to do that." In deposition testimony, Collins said he did not speak for the District.

Dr. HaLevi wrote a letter to the Post and Courier after the incident. He noted that educators were prohibited by law from commenting on ongoing disciplinary issues. He discussed the challenges that he and the staff at Clark Academy encountered in dealing with at-risk students. He stated that "each student we fail to reach is a tragedy for the entire Charleston community."

The District investigated the dress code incident and made findings in a confidential report on April 29, 2016, concluding that Dr. HaLevi did not act appropriately. The District recommended that Dr. HaLevi be suspended, dismissed, or removed from Clark Academy.

Dr. HaLevi sent numerous letters to various District officials and eventually followed the grievance process whereupon the District classified his complaints as a grievance and responded to it. It appears the District sent Dr. HaLevi a new "draft" grievance procedure in November 2016. In May 2017, after reviewing the grievance and all information regarding the dress code incident, the District Superintendent (the Superintendent) found that Dr. HaLevi did not exercise good judgment. The Superintendent noted that Dr. HaLevi's handling of the dress code incident alone was sufficient to warrant his reassignment. To rebut Dr. HaLevi's claims that the District had not kept him apprised of his employment status, she outlined four instances of communication between April 24, 2016, and July 28, 2016, from the District to Dr. HaLevi about his status in the District. Dr. HaLevi was neither terminated from the District nor suspended without pay. He left the District in 2017. 1

Dr. HaLevi sued the District for defamation, a due process violation, and breach of the covenant of good faith and fair dealing. The circuit court granted summary judgment to the District on all claims, and this appeal followed.

ISSUE ON APPEAL

Did the circuit err in granting summary judgment to the District?

STANDARD OF REVIEW

"Rule 56(c) of the South Carolina Rules of Civil Procedure provides that the moving party is entitled to summary judgment 'if the [evidence before the court] show[s] that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.'" Kitchen Planners, LLC v. Friedman, 440 S.C. 456, 459, 892 S.E.2d 297, 297 (2023) (quoting Rule 56(c), SCRCP). "When determining if any triable issues of fact exist, the evidence and all reasonable inferences must be viewed in the light most favorable to the non- moving party." Callawassie Island Member Club, Inc. v. Martin, 437 S.C. 148, 157, 877 S.E.2d 341, 345 (2022).

LAW/ANALYSIS

I. Defamation and Defamation by Innuendo

Dr. HaLevi argues a jury "could find that [the District's] actions clearly inferred that [Dr. HaLevi] was unfit for his job. His complaint contended the District defamed him by placing him on leave, by not defending him in the press as they had done for other employees, and by demoting him.

In order to prove defamation, the plaintiff must show (1) a false and defamatory statement was made; (2) the unprivileged publication was made to a third party; (3) the publisher was at fault; and (4) either actionability of the statement irrespective of special harm or the existence of special harm caused by the publication.

1 Dr. HaLevi currently lives and works in Israel. Erickson v. Jones St. Publishers, LLC, 368 S.C. 444, 465, 629 S.E.2d 653, 664 (2006).

To render [a] defamatory statement actionable, it is not necessary that the false charge be made in a direct, open and positive manner. A mere insinuation is as actionable as a positive assertion if it is false and malicious and the meaning is plain. Statements therefore may be either defamatory on their face, or defamatory by way of innuendo. Innuendo is extrinsic evidence used to prove a statement's defamatory nature. It includes the aid of inducements, colloquialisms, and explanatory circumstances.

Fountain v. First Reliance Bank, 398 S.C. 434, 441–42, 730 S.E.2d 305, 309 (2012).

We find the evidence and all reasonable inferences do not show a genuine issue of material fact as to whether the District defamed Dr. HaLevi by innuendo. Dr. HaLevi has not shown that the District was under any obligation to comment on his behalf, regardless of whether it chose to speak on other issues in the past. Dr. HaLevi's other claims outlined above relate to internal administrative findings and were not "mere insinuations" and were not "false and malicious" with a plain meaning. The District investigated Dr. HaLevi's handling of the dress code violation and sent him communications and findings regarding that investigation. These communications and findings were not available to the public, do not correspond to the Erickson or Fountain factors outlined above, and were not defamatory.

The circuit court also found that the District was not a proper defendant regarding statements made by board member Chris Collins. The circuit court also found Dr. HaLevi was a public official and barred from asserting a defamation claim against the District under the South Carolina Tort Claims Act.

Dr. HaLevi argues that Chris Collins made defamatory statements in his official capacity as a board member of the District. He contends Collins's testimony that he did not act as the District's agent at the time the statements were made is irrelevant. We disagree.

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Cite This Page — Counsel Stack

Bluebook (online)
Andrew HaLevi PHD v. Charleston County School, Counsel Stack Legal Research, https://law.counselstack.com/opinion/andrew-halevi-phd-v-charleston-county-school-scctapp-2024.