Boye, D. v. McCarthy, D.

CourtSuperior Court of Pennsylvania
DecidedJuly 19, 2022
Docket1538 MDA 2021
StatusUnpublished

This text of Boye, D. v. McCarthy, D. (Boye, D. v. McCarthy, D.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Boye, D. v. McCarthy, D., (Pa. Ct. App. 2022).

Opinion

J-S16020-22

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

DANIEL BOYE : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : v. : : DEBRA MCCARTHY : No. 1538 MDA 2021

Appeal from the Order Entered October 19, 2021, in the Court of Common Pleas of Luzerne County, Civil Division at No(s): 2021-00941.

BEFORE: PANELLA, P.J., KUNSELMAN, J., and COLINS, J.*

MEMORANDUM BY KUNSELMAN, J.: FILED: JULY 19, 2022

I. Introduction

In this defamation case, Daniel Boye, a Luzerne County college student,

appeals from the order sustaining preliminary objections in the nature of a

demurrer to his complaint against Debra McCarthy, a resident of New York.1

Mr. Boye alleges Ms. McCarthy libeled him. According to the complaint, Ms.

McCarthy sent a false e-mail to an administrator at Mr. Boye’s college. She

alleged that Mr. Boye raped a third party in his dorm room.

The trial court held that, as a matter of law, Ms. McCarthy’s e-mail was

a privileged communication and, therefore, incapable of forming the basis of

a defamation claim. It also ruled that Mr. Boye’s complaint lacked sufficient ____________________________________________

* Retired Senior Judge assigned to the Superior Court.

1 Initially, Ms. McCarthy attempted to remove this matter to the United States District Court for the Middle District of Pennsylvania on diversity-of-citizenship grounds. On April 5, 2021, the federal court denied her request and remanded the case to the Court of Common Pleas of Luzerne County. J-S16020-22

factual allegations to establish that Ms. McCarthy abused, and thus waived,

the privilege. We disagree with the trial court’s interpretation of the facts

alleged in the complaint, reverse, and remand for further proceedings.

II. Facts Alleged in the Complaint

The complaint2 alleges the following facts: Mr. Boye and Jane Roe

attend a private college in Pennsylvania. They became sexual partners for a

time and “then stopped talking to each other.” Complaint at 1, ¶ 3.

A few months later, Mr. Boye exited his dorm room to find Ms. Roe

naked in the hallway, where she appeared to be having sex with another

student (“Partner #1”). Neither Ms. Roe nor Partner #1 lived in Mr. Boye’s

residence hall. See id. at 2.

Shortly thereafter, Ms. Roe “forced her way into [Mr. Boye’s] room and

proceeded to have sexual intercourse with him.” Id. at 2, ¶ 6. The following

morning, a video recording displayed Mr. Boye escorting “a smiling Jane Roe

____________________________________________

2 Under our scope of review discussed below, we must accept the facts alleged in Mr. Boye’s complaint as true, because we are reviewing an order that dismissed his case on preliminary objections.

Also, in the complaint, Mr. Boye identified himself and the third party as “John Doe” and “Jane Roe,” respectively. However, in resolving Ms. McCarthy’s preliminary objections, the trial court ordered Mr. Boye to “use his legal name on any further filings and submissions.” Trial Court Opinion, 10/19/21, at 6. Mr. Boye did not appeal that decision, and he uses his legal name in this Court. Thus, we use Mr. Boye’s name in the factual recitation, rather than “John Doe,” and that pseudonym no longer appears in the case’s caption.

-2- J-S16020-22

back to her own dorm.” Id. at 2, ¶ 7. Later that day, Ms. Roe “stated that

she had been drugged and sexually assaulted.” Id. at 2, ¶ 8.

Next, Ms. McCarthy, who was not present for the above events, e-mailed

an administrator at Mr. Boye’s private college. Therein, she falsely accused

Mr. Boye of:

[telling] another student that [Partner #1] was forcing Jane Roe as she was blacked out to perform a sex act upon him and that [Mr. Boye] got Jane Roe away from him and then performed a non-consensual intercourse on Jane Roe.

[Mr. Boye] is bragging to other [college] students he had 3 hours of non-consensual sex on blacked-out Jane Roe.

Jane Roe cannot remember anything other than being in [the] hallway of [the] dormitory and believes she was roofied in a dorm room that [Partner #1] was in earlier in the evening.

While the investigation is taking place, how [can] Jane Roe feel safe with [Partner #1,] a 6 ft, 300-pound assailant and his co-perpetrator on campus[?]

Id. at 2-3, ¶ 10 (some punctuation and capitalizations omitted).

“Ms. McCarthy made no effort to contact [Mr. Boye] to check the truth

of her defamatory and malicious assertions stated in that e-mail.” Id. at 3, ¶

11. Additionally, she sent it with absolutely no regard for the falsehoods it

states and which she admits she knew about at that time in the very same e-

mail.” Id. at 5-6, ¶ 26. Instead of giving a firsthand account of events (or

even a hearsay recitation of Ms. Roe’s recollection), Ms. McCarthy

“manufactured all the vitriol stated in the September 16, 2020 e-mail and

knowingly published it to harm [Mr. Boye].” Id. at 6, ¶ 26.

-3- J-S16020-22

Ms. McCarthy’s false accusations lowered Mr. Boye’s reputation in the

college community and his hometown, because she wrongly “labeled him as a

man who would rape Jane Roe for three hours and then brag about it to his

friends.” Id. at 6, ¶ 29. Ms. McCarthy wrote her libelous e-mail with the hope

of getting Mr. Boye expelled or otherwise injuring his college career. Hence,

Mr. Boye suffered harm to his reputation. See id. at 7.

III. Procedural Background

Mr. Boye initiated this lawsuit on January 27, 2021. In his complaint,

he alleged three counts against Ms. McCarthy: Defamation, Defamation Per

Se, and False Light.

Ms. McCarthy filed five preliminary objections. First, she objected, in

the nature of a demurrer to the entire complaint. To support that objection,

Ms. McCarthy claimed her e-mail was conditionally privileged. Second, she

objected to Mr. Boye using “John Doe” to identify himself. Third, she

demurred specifically to the count of False Light. Fourth, Ms. McCarthy sought

dismissal of punitive damages. And fifth, she objected to the lack of an

appropriate verification, because Mr. Boye filed the complaint with a redacted

signature.

Mr. Boye filed a reply to the preliminary objections, a brief in opposition,

and supplemental response to the preliminary objections. In his reply and

brief in opposition, Mr. Boye asserted that Ms. McCarthy abused/waived the

conditional privilege, because she acted with malice or negligence.

-4- J-S16020-22

In his supplemental response, Mr. Boye also challenged Ms. McCarthy’s

claim that the e-mail was conditionally privileged. He asserted that no such

privilege existed, because the privilege only applies to communications before

quasi-judicial proceedings of government-run entities. Here, the college

administrator worked for a private institution; thus, Mr. Boye argued the

conditional privilege could not apply to Ms. McCarthy’s libelous e-mail.

Sustaining the first preliminary objection, the trial court stated, “It is

clear and free from doubt that [Ms. McCarthy’s] e-mail, as alleged in the

complaint, was privileged.” Trial Court Opinion, 10/19/21, at 4. The court

ruled Ms. McCarthy had an interest in protecting the welfare of Jane Roe,

because Ms. Roe was Ms. McCarthy’s daughter.3 It further ruled that the

administrator had an interest in protecting the college’s students from violent,

sexual offenses while on campus.

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Boye, D. v. McCarthy, D., Counsel Stack Legal Research, https://law.counselstack.com/opinion/boye-d-v-mccarthy-d-pasuperct-2022.