Bertell Ollman v. Rowland Evans, Robert Novak

713 F.2d 838, 230 U.S. App. D.C. 44
CourtCourt of Appeals for the D.C. Circuit
DecidedOctober 6, 1983
Docket79-2265
StatusPublished
Cited by15 cases

This text of 713 F.2d 838 (Bertell Ollman v. Rowland Evans, Robert Novak) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bertell Ollman v. Rowland Evans, Robert Novak, 713 F.2d 838, 230 U.S. App. D.C. 44 (D.C. Cir. 1983).

Opinions

PER CURIAM:

The judgment of the District Court is reversed and the case is remanded to the District Court for further proceedings. Chief Judge Robinson concurs in the judgment for the reasons set forth in his opinion. Circuit Judge Wald concurs in the remand for the reasons set forth in her opinion. Senior Circuit Judge MacKinnon concurs in the remand subject to the principles set forth in his opinion.

ROBINSON, Chief Judge:

This defamation suit is now before this court on the District Court’s grant of summary judgment for the defense.1 The appeal presents one major issue: Are allegedly defamatory statements of which the appellant complains representations of fact capable of supporting an action for libel or expressions of opinion unconditionally protected by the First Amendment? Because I think there may well be material issues of fact affecting the availability of the opinion privilege for several of the statements, I would reverse the judgment of the District Court and remand the case for further proceedings.

I

The appellant, Bertell Oilman, is a Marxist professor of political science.2 In March, 1978, a search committee composed of political scientists at the University of Maryland nominated Oilman to head that institution’s Department of Politics and Government.3 The nomination was approved by the Provost of the University and the Chancellor of the College Park campus, and allegedly was faring quite well until the event precipitating this litigation transpired.4

The appellees, Rowland Evans and Robert Novak, are authors of a widely-published syndicated column.5 On May 4,1978, an article they prepared on Oilman’s candidacy appeared in the Washington Post and other newspapers across the country.6 Captioned “The Marxist Professor’s Intentions,” this column touched briefly on an asserted “public debate” over the propriety of Oilman’s nomination, and then focused on what the authors denominated the “central question”:

... not Oilman’s beliefs, but his intentions. His candid writings avow his desire to use the classroom as an instrument for preparing what he calls “the revolution.” Whether this is a form of indoctrination that could transform the real function of a university and transcend limits of academic freedom is a concern to academicians who are neither McCarthyite nor know-nothing.7

There followed several paragraphs which, by selected quotations from Oilman’s writings, tended to suggest that Oilman regards the classroom as a forum for winning adherents to Marxism. The article then asserted:

Such pamphleteering is hooted at by one political scientist in a major eastern university, whose scholarship and reputation as a liberal are well known. “Oilman has no status within the profession, but is a pure and simple activist,” he said.

Confiding that “[wjhile Oilman is described in news accounts as a ‘respected Marxist scholar,’ he is widely viewed in his profession as a political activist,” the column described Oilman as “an outspoken proponent [840]*840of ‘political Marxism.’ ” It concluded by posing several questions:

What is the true measurement of Oilman’s scholarship? Does he intend to use the classroom for indoctrination? Will he indeed be followed by other Marxist professors? Could the department in time be closed to non-Marxists, following the tendency at several English universities?

Deeming libelous several statements and innuendoes in this piece, Oilman, through his counsel, wrote to Evans and Novak demanding that they print a retraction.8 This they declined to do.9 Ultimately, Oilman was denied the departmental chairmanship.10 He alleges that loss of this post was attributable to false and defamatory statements in the column;11 additionally, he avers that it damaged his reputation as a “scholar of integrity” and caused him “great distress and mental anguish.”12 Charging Evans and Novak with actual malice, he seeks punitive as well as compensatory damages.13

Evans and Novak moved for judgment on the single ground that “all of the allegedly libelous statements are statements of opinion protected by the First and Fourteenth Amendments to the Constitution of the United States.”14 The District Court agreed, characterizing the complained-of passages as “opinions,” “conclusions,” and “interpretations,” all of which in its view were constitutionally insulated.15 Perceiving no indication that any of the supporting data outlined in the column were false, and discerning no implication that there existed other, undisclosed facts that were defamatory, the court granted the motion.16 On appeal, Oilman attacks each facet of the court’s reasoning.

II

The First Amendment embodies a special solicitude for unfettered expression of opinion. That proposition is traceable to Gertz v. Robert Welch, Inc.,17 where the Court stated:

We begin with the common ground. Under the First Amendment there is no such thing as a false idea. However pernicious an opinion may seem, we depend for its correction not on the conscience of [841]*841judges and juries but on the competition of other ideas.18

While this passage was the first clear verbalization of the degree to which the Constitution preempts local libel laws in the area of defamatory opinion, the Court previously had hinted at limitations on governmental power to impose civil or criminal liability for statements of belief, judgment, or sentiment. In New York Times Co. v. Sullivan, the landmark decision that first explicated the interplay between constitutional guarantees of free speech and press and common law sanctions for defamatory misstatement, the Court observed:

Since the Fourteenth Amendment requires recognition of the conditional privilege for honest misstatements of fact, it follows that a defense of fair comment must be afforded for honest expressions of opinion based upon privileged, as well as true, statements of fact. Both defenses are of course defeasible if the public official proves actual malice....19

And in Garrison v. Louisiana, a prosecution for criminal libel, the Court again adverted to fair comment, finding it unnecessary to decide in the context of that case “whether appellant’s statement was factual or merely comment, or whether a State may provide any remedy, civil or criminal, if defamatory comment alone, however vituperative, is directed at public officials.”20

The opinion privilege set out in Gertz thus was foreshadowed in earlier pronouncements, although the degree of constitutional protection to be afforded statements of belief, judgment, or interpretation — a protection seemingly absolute under the Gertz formulation — might not have been fully anticipated. But while Gertz

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Bertell Ollman v. Rowland Evans, Robert Novak
713 F.2d 838 (D.C. Circuit, 1983)

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713 F.2d 838, 230 U.S. App. D.C. 44, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bertell-ollman-v-rowland-evans-robert-novak-cadc-1983.