Carr v. Educational Theatre Assn.

2023 Ohio 1681, 215 N.E.3d 584
CourtOhio Court of Appeals
DecidedMay 19, 2023
DocketC-220240
StatusPublished
Cited by4 cases

This text of 2023 Ohio 1681 (Carr v. Educational Theatre Assn.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carr v. Educational Theatre Assn., 2023 Ohio 1681, 215 N.E.3d 584 (Ohio Ct. App. 2023).

Opinion

[Cite as Carr v. Educational Theatre Assn., 2023-Ohio-1681.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

DIANE M. CARR, : APPEAL NO. C-220240 TRIAL NO. A-2101599 Plaintiff-Appellant, :

: VS. O P I N I O N. :

EDUCATIONAL THEATRE : ASSOCIATION, : and : JULIE C. THEOBALD,

Defendants-Appellees. :

Civil Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: May 19, 2023

Freking Myers & Reul LLC and George M. Reul, Jr., for Plaintiff-Appellant,

Jackson Lewis P.C., Ryan M. Martin and Alessandro Botta Blondet, for Defendants- Appellees. OHIO FIRST DISTRICT COURT OF APPEALS

BERGERON, Judge.

{¶1} After pressing “send” on an email, defendants-appellees Educational

Theatre Association (“EdTA”) and then-executive director of EdTA, Julie Theobald

(collectively “the EdTA defendants”), found themselves on the receiving end of a

lawsuit. Although she was not explicitly named in the email, plaintiff-appellant Dr.

Diane Carr claimed that the email defamed her. She maintained, throughout this

litigation, that the email constituted defamation per se, but she also acknowledged

that the defamatory effect could only be appreciated by implication or innuendo.

Seeing nothing actionable in the email, the trial court eventually granted summary

judgment in favor of the EdTA defendants. After careful review of the email and

governing caselaw, we agree with the trial court’s conclusion and affirm its

judgment.

I.

{¶2} Dr. Carr joined EdTA, a nonprofit that promotes theatre education in

schools, in 2004, and she eventually worked her way up to Executive Director in

2011. In 2013, Ms. Theobald asked Dr. Carr to oversee the International Thespian

Officer (“ITO”) program and the students who participated in that program.

Several years later, in March 2019, Dr. Carr learned that EdTA would terminate her

in May 2019 based on her job performance. Although Dr. Carr disagreed with the

decision, she negotiated a separation agreement that released all claims she might

possess against EdTA and its employees.

{¶3} In August 2019, EdTA received complaints from ITO student

participants concerning Dr. Carr’s conduct and, through outside counsel, notified

her generally about the allegations—but EdTA declined to reveal the substance of

2 OHIO FIRST DISTRICT COURT OF APPEALS

the allegations other than to indicate that they did not involve physical abuse. EdTA

also notified Dr. Carr that it would hire an independent firm to investigate the

allegations, and it requested that she cooperate in the investigation. The record,

however, fails to illuminate the results of any investigation.

{¶4} Nevertheless, according to the EdTA defendants, in June 2020, new

information and complaints about the ITO program during Dr. Carr’s tenure

surfaced. Around the same time, Dr. Carr accepted a speaking engagement at a

virtual student leadership event (i.e., a Zoom event) hosted by six EdTA state

chapters. Upon discovering that Dr. Carr—and another ITO adult liaison also a

subject of the complaints—would speak at the event, Ms. Theobold and the EdTA

board of directors dispatched the following email, which we reproduce in full:

Dear Chapter Directors from Alabama, Georgia, Missouri, New Jersey, North Carolina, and Washington,

Cc: All Chapter Directors, EdTA Board, Julie Theobald, Brian Monk, Hans Weichhart, Allison Dolan, Sarah Etheridge, Olivia Micer, Shaila Seth

In our Association, the well-being of our students is our highest priority. According to the EdTA Code of Professional Standards, as professional members of EdTA, we shall maintain a professional relationship with students both in and outside of the classroom and consider the well-being of students in all decisions and actions. It is with this in mind that we are compelled to communicate with urgency.

It has come to our attention that the chapters of Alabama, Georgia, Missouri, New Jersey, North Carolina, and Washington plan to host a virtual student leadership event this week for STOs from these chapters. Some of the past ITO adult liaisons from 2013-2019 are participating in this week’s STO leadership event.

We urge you to postpone this event.

3 OHIO FIRST DISTRICT COURT OF APPEALS

As a reminder, in the summer of 2019 we conducted an ITO program review. One of the reasons for this review was that concerns were raised by former ITO members who served from 2013-2019 about the treatment of students by the adult ITO liaisons who served during that time period. These concerns include allegations of negligence and emotional abuse.

We took steps forward to ensure the safety of the 2019-2020 ITO and future ITOs and STOs. We are acknowledging there is more work to be done in the interest of the well-being of students.

We have received new information in the past couple of weeks that gives additional insight and severity to the 2019 program review. It is our duty to conduct a full investigation on all sides of these allegations, and we will need time to follow through and come to appropriate resolutions.

We urge you to postpone the leadership event while we take steps to fully address the situation. If you are unwilling to postpone this event, we will communicate to the members in your chapters that this event is not sanctioned by EdTA, that we have concerns about the event, and that we cannot assure the participants and parents that student safety will be protected.

Separately, we also have concerns about the secretive nature of this event, given the discussions held at Summit last year about the need for communication and transparency. We have heard from multiple sources that members were asked to keep it a secret.

Please confirm whether you will postpone the event. We commit to sharing further information in the future.

With respect,

EdTA Board of Directors

[List of Board of Directors]

Julie Theobald, Executive Director

CC: Scott Wilson and Erin Carr, recused due to Conflict of Interest

4 OHIO FIRST DISTRICT COURT OF APPEALS

In the aftermath of this email, Dr. Carr filed a complaint in May 2021 against the

EdTA defendants for breach of contract—concerning the separation agreement

referenced above—and defamation per se largely based on the email.

{¶5} Several months later, the EdTA defendants filed a motion for

judgment on the pleadings, arguing that Dr. Carr purported to bring an

impermissible implied defamation claim, without actually quoting or attaching the

email, and that Ohio does not permit implied defamation claims. In response, Dr.

Carr largely argued that the EdTA defendants knew there was no safety risk if she

attended the Zoom event, yet the “clear impact” of the email was defamatory since

it conveyed that her attendance would endanger student safety. She further

maintained that referencing an “investigation” suggested that the EdTA defendants

had first-hand knowledge that substantiated the alleged risk to the participants of

the conference, and that no innocent meaning can arise from the statement “that

[the EdTA defendants] cannot assure the participants and parents that student

safety will be protected.” During the briefing on this motion, the EdTA defendants

attached the full text of the email to their reply—via an affidavit of Ms. Theobald—

acknowledging that the court may wish to convert their motion into a motion for

summary judgment in order to consider the email. See Daniely v.

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Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 1681, 215 N.E.3d 584, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carr-v-educational-theatre-assn-ohioctapp-2023.