Blue Ridge Bank v. Veribanc, Inc.

675 F. Supp. 1007, 1987 U.S. Dist. LEXIS 11870, 1987 WL 24567
CourtDistrict Court, W.D. Virginia
DecidedNovember 19, 1987
DocketCiv. A. No. 83-0683(R)
StatusPublished

This text of 675 F. Supp. 1007 (Blue Ridge Bank v. Veribanc, Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Blue Ridge Bank v. Veribanc, Inc., 675 F. Supp. 1007, 1987 U.S. Dist. LEXIS 11870, 1987 WL 24567 (W.D. Va. 1987).

Opinion

MEMORANDUM OPINION

TURK, Chief Judge.

This case is before the court on the defendant’s post trial motions for a judgment notwithstanding the verdict, or for a new trial. Jurisdiction is based on diversity, and is proper in this court, as ruled by the Fourth Circuit in Blue Ridge Bank v. Veribanc, 755 F.2d 371 (4th Cir.1985). In September, the court presided over a four day trial in which a jury awarded Blue Ridge Bank $600,000.00 for damages caused by Veribanc’s libel of the plaintiff.

I. Facts

Blue Ridge Bank operated as a savings and loan institution in the town of Floyd, in Floyd County, Virginia until November 18, 1982. On that date it became a member bank of the federal reserve system, and accordingly became responsible for complying with the regulations of the Federal Reserve Board. The plaintiff generated wide spread publicity in Floyd County concerning its conversion to a commercial bank, in an effort to attract customers at a time when the savings and loan industry was having trouble.

Veribanc is a company based in Wake-field, Massachusetts that buys computerized information available from the Federal Reserve Board. Veribanc processes this information into a useful format, and then sells these reports to the public. Veribanc produces numerous reports routinely, as well as several individual reports that are requested on a one time basis. The report in issue was not generated as one of Veri-banc’s routine reports, but was generated by Veribanc and provided to syndicated newspaper columnist Dan Dorfman with the understanding that he would credit Veribanc as the source of his information if he used it. The report was purportedly a list of banks that, if they continued their present pattern as indicated by the figures released by the Federal Reserve Board for the fourth quarter of 1982, would reach [1009]*1009zero equity within twelve months. The figures were arrived at by taking the fourth quarter loss, as reported to the Federal Reserve, multiplying it by four to produce an annual loss figure, and comparing this figure to the bank’s reported equity.

It was not disputed at trial that Blue Ridge Bank had, for the period ending in December 1982, filed a “call report” as required with the Federal Reserve, showing a substantial loss. The figure actually reported the total loss for the year 1982 incurred by the institution, both as a savings and loan, and as a commercial bank. According to testimony at trial from Mr. John W. Scott, an employee of the Federal Reserve Board, the report was filed in accordance with the regulations then in effect.

Veribanc, through its computer program, interpreted the loss reported by Blue Ridge Bank as being a quarterly loss, rather than an annual loss, because no figure had been reported for Blue Ridge Bank at the end of the third quarter. No third quarter figure had been reported because as a savings and loan, Blue Ridge Bank was not required to report to the Federal Reserve. Only after converting to a commercial bank was Blue Ridge Bank required to file these reports.

Veribanc asserted at trial that it had no way of knowing that the loss figure reported was actually an annual, instead of a quarterly, loss. The plaintiff strongly contested this claim.

As a result of this error, Veribanc grossly exaggerated Blue Ridge Bank’s financial position, and included Blue Ridge Bank on its list of 126 banks “which could reach zero equity within one year.” The fact that this calculation was in error was admitted at trial by Warren G. Heller, Treasurer and Director of Veribanc.

Veribanc provided its list of banks that could be in trouble to syndicated newspaper columnist Dan Dorfman. In sending the list to Mr. Dorfman, Veribanc couched its report with a number of caveats, including some warnings that: the list was based on preliminary data, had not been independently verified, other more current data may be available, and the list was not an expression of opinion by Veribanc or the Federal Reserve that any of the banks were' in trouble. Mr. Dorfman did not include all of Veribanc’s caveats in his newspaper column, and when the Richmond Times-Dispatch published the column, it removed some of the caveats that Mr. Dorfman had included. The only place Blue Ridge Bank was mentioned in the article was in a table prepared by Veribanc listing the banks singled out as those that could reach zero equity within one year. Neither Mr. Dorfman nor the newspaper altered this table, except the newspaper published only those banks the paper felt to be of local interest. The table headings and contents were otherwise unchanged.

II. Legal Standards

1) Public Figure

Any consideration of the law of libel starts, of necessity, with the case of New York Times v. Sullivan, 376 U.S. 254, 84 S.Ct. 710, 11 L.Ed.2d 686 (1964).

It was in this case that the court first differentiated between the proof required by a public official and a private person, to recover an award based on a defamation claim. The court considered the applicability of the New York Times decision to public figures in Curtis Publishing v. Butts, 388 U.S. 130, 87 S.Ct. 1975, 18 L.Ed.2d 1094 (1967), and to private persons in Gertz v. Robert Welch, Inc., 418 U.S. 323, 94 S.Ct. 2997, 41 L.Ed.2d 789 (1974).

Defamation law has become more complex as the Court has recognized the necessity of curtailing the common law slander and libel causes of action to the extent they interfere with the freedoms of speech and press as guaranteed by the first amendment. New York Times, 376 U.S. at 268-69, 84 S.Ct. at 719-20. The court has considered and weighed many competing interests in developing the appropriate standards. As discussed in Gertz, 418 U.S. at 339-49, 94 S.Ct. at 3006-12, these include the need for a vibrant free press not unnecessarily inhibited by the threat of costly law suits, the need for open public discussion over matters that affect the public, [1010]*1010and “the individual’s right to the protection of his own good name.” Id. at 341, 94 S.Ct. at 3008. It is because of this last element that the press has not been granted absolute immunity.

In Gertz, the Supreme Court held that the states could define the appropriate standard of liability for media defendants sued by private individuals. Accordingly, if this court were to hold that Blue Ridge Bank was a private figure, it would look to Virginia law to determine the appropriate standard. For public figure and public official plaintiffs, the standard has been determined as a matter of federal constitutional law, New York Times, 376 U.S. 254, 84 S.Ct. at 710; Curtis Publishing, 388 U.S. 130, 87 S.Ct. 1975.

Whether or not a plaintiff is a public figure or public official is a question of law for the court to decide. Rosenblatt v. Baer, 383 U.S. 75

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Related

New York Times Co. v. Sullivan
376 U.S. 254 (Supreme Court, 1964)
Rosenblatt v. Baer
383 U.S. 75 (Supreme Court, 1966)
Curtis Publishing Co. v. Butts
388 U.S. 130 (Supreme Court, 1967)
St. Amant v. Thompson
390 U.S. 727 (Supreme Court, 1968)
Gertz v. Robert Welch, Inc.
418 U.S. 323 (Supreme Court, 1974)
Wolston v. Reader's Digest Assn., Inc.
443 U.S. 157 (Supreme Court, 1979)
Blue Ridge Bank v. Veribanc, Inc.
755 F.2d 371 (Fourth Circuit, 1985)
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Reliance Insurance Co. v. Barron's
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Coronado Credit Union v. Koat Television, Inc.
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675 F. Supp. 1007, 1987 U.S. Dist. LEXIS 11870, 1987 WL 24567, Counsel Stack Legal Research, https://law.counselstack.com/opinion/blue-ridge-bank-v-veribanc-inc-vawd-1987.