Celanese, Ltd. v. James E. Johnston

CourtCourt of Appeals of Texas
DecidedJanuary 27, 2005
Docket13-02-00097-CV
StatusPublished

This text of Celanese, Ltd. v. James E. Johnston (Celanese, Ltd. v. James E. Johnston) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Celanese, Ltd. v. James E. Johnston, (Tex. Ct. App. 2005).

Opinion

NUMBER 13-02-097-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG


CELANESE, LTD.                                                                       Appellants,

v.

JAMES E. JOHNSTON,                                                                 Appellee.




On appeal from the County Court at Law No 4

of Nueces County, Texas.





M E M O R A N D U M O P I N I O N


     Before Chief Justice Valdez and Justices Rodriguez and Dorsey


                             Opinion by Chief Justice Valdez

       James E. Johnston brought suit against his former employer, Celanese Ltd., for breach of contract and defamation after Celanese terminated him, putatively on grounds that Johnston allegedly falsified an expense report. A jury found in favor of Johnston on the breach of contract and defamation claims, and further found that Celanese acted with malice regarding the defamation. The trial court entered judgment in accordance with the verdict. Celanese raises eleven issues on appeal. We reform the award of exemplary damages against Celanese, and, as reformed, affirm the trial court's judgment.

         As this is a memorandum opinion and the parties are familiar with the facts, we will not recite them here except as necessary to advise the parties of the Court’s decision and the basic reasons for it. See Tex. R. App. P. 47.4.

Defamation

         Celanese’s fourth, fifth, sixth, seventh, and eighth issues concern the jury’s findings regarding defamation. The jury found that Celanese’s statements concerning the termination of Johnston’s employment for “falsification of company documents” constituted slander per se and libel per se, and further found from “clear and convincing evidence” that Celanese’s defamatory conduct was performed with actual malice.

         In Celanese’s fourth issue, it argues that Johnston cannot recover for defamation per se given that the statements at issue were subject to a qualified privilege and there is no evidence of actual malice. In its fifth issue, Celanese asserts that the evidence is legally and factually insufficient to support the jury’s finding of actual malice.

         A defamatory statement may be subject to a conditional or qualified privilege, which arises out of the circumstances in which an allegedly false statement is published in a lawful manner for a lawful purpose. Hearst Corp. v. Skeen, 130 S.W.3d 910, 926 (Tex. App.–Fort Worth 2004, pet. filed). An interest giving rise to a qualified privilege may be that of the publisher of the communication, the recipient of the communication, or a third person. TRT Dev. Co.-KC v. Meyers, 15 S.W.3d 281, 286 (Tex. App.–Corpus Christi 2000, no pet.); Pioneer Concrete of Tex., Inc. v. Allen, 858 S.W.2d 47, 50 (Tex. App.–Houston [14th Dist.] 1993, writ denied). Similarly, an employer has a conditional or qualified privilege that attaches to communications made in the course of an investigation following a report of employee wrongdoing. Randall's Food Mkts., Inc. v. Johnson, 891 S.W.2d 640, 646 (Tex. 1995); Austin v. Inet Techs., Inc., 118 S.W.3d 491, 496 (Tex. App.–Dallas 2003, no pet.). The privilege remains intact as long as communications pass only to persons having an interest or duty in the matter to which the communications relate. Austin, 118 S.W.3d at 496.

         In the instant case, the parties stipulated that the communications at issue were subject to a conditional or qualified privilege. However, a conditional or qualified privilege is defeated when the privilege is abused, such as when the person making the defamatory statement acts with actual malice. TRT Dev. Co.-KC, 15 S.W.3d at 286; Grant v. Stop-N-Go Mkt. of Tex., Inc., 994 S.W.2d 867, 874 (Tex. App.–Houston [1st Dist.] 1999, no writ); see Hearst Corp., 130 S.W.3d at 926.

         In the context of a defamation claim, actual malice means knowledge of, or reckless disregard for, the falsity of a statement. Bentley v. Bunton, 94 S.W.3d 561, 591 (Tex. 2002). Reckless disregard is a subjective standard that focuses on the conduct and state of mind of the defendant. Id. It requires more than a departure from reasonably prudent conduct, and accordingly, mere negligence is not enough. Id. There must be evidence that the defendant in fact entertained serious doubts as to the truth of his publication or evidence that the defendant actually had a high degree of awareness of the probable falsity of his statements. Bentley, 94 S.W.3d at 591. Thus, for example, the failure to investigate the facts before speaking as a reasonably prudent person would do is not, standing alone, evidence of a reckless disregard for the truth, but evidence that a failure to investigate was contrary to a speaker's usual practice and motivated by a desire to avoid the truth may demonstrate the reckless disregard required for actual malice. Id.

         A plaintiff is entitled to prove the defendant's state of mind through circumstantial evidence. Bentley, 94 S.W.3d at 591. The evidence necessary to prove malice must be “clear and convincing.” See Tex. Civ. Prac. & Rem. Code Ann. § 41.003(a)(2) (Vernon Supp. 2004); Forbes, Inc. v. Granada Biosciences, Inc., 124 S.W.3d 167, 171 (Tex. 2003). Clear and convincing evidence is that measure or degree of proof that will produce in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established. Tex. Civ. Prac. & Rem. Code Ann. § 41.001(2) (Vernon Supp. 2004); Transp. Ins. Co. v. Moriel, 879 S.W.2d 10, 31 (Tex. 1994).

         

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