Douglas v. Pratt

2000 DNH 199
CourtDistrict Court, D. New Hampshire
DecidedSeptember 29, 2000
DocketCV-98-416-M
StatusPublished
Cited by1 cases

This text of 2000 DNH 199 (Douglas v. Pratt) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Douglas v. Pratt, 2000 DNH 199 (D.N.H. 2000).

Opinion

Douglas v . Pratt CV-98-416-M 09/29/00 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Charles G. Douglas, III and Edward E . Hewson, Plaintiffs

v. Civil N o . 98-416-M Opinion N o . 2000 DNH 199 Shannon Pratt and Associated Press, Defendants

O R D E R

Plaintiffs Charles G. Douglas, I I I , and Edward E . Hewson

allege that the Associated Press (AP) and Shannon Pratt defamed

them in a March 1 5 , 1998, article released by the AP (Count I ) .

Additionally, Counts I I I , IV, and V raise various claims sounding

in negligence and Count VI alleges that the AP’s actions violated

the New Hampshire Consumer Protection Act, N.H. RSA 358-A, et

seq. Douglas further alleges that the statements and the article

place him in a false light (Count I I ) . Defendants have filed

motions for judgment on the pleadings (document nos. 80 and 8 2 ) .

See Fed. R. Civ. P. 12(c). Plaintiffs object. Standard of Review

Federal Rule of Civil Procedure 12(c) provides that,

“[a]fter the pleadings are closed but within such time as not to

delay the trial, any party may move for judgment on the

pleadings.” In reviewing such a motion, the court must credit

all material allegations in the complaint as true and draw all

reasonable inferences in the non-moving party’s favor. See

Feliciano v . State of Rhode Island, 160 F.3d 7 8 0 , 788 (1st Cir.

1998). The court may grant a motion for judgment on the

pleadings only if it appears beyond doubt that the plaintiffs can

prove no set of facts in support of their claims that would

entitle them to relief. See Gaskell v . The Harvard Cooperative

Society, 3 F.3d 495, 497-98 (1st Cir. 1993).

Factual Background1

On March 1 5 , 1998, an article appeared on page A10 of the

Portsmouth Sunday Herald entitled, “Caroline Douglas claims

1 This recitation of facts is based on Plaintiffs’ Third Amended Complaint and Plaintiffs’ memoranda in opposition to the present motion. They are taken as true for the purposes of this motion only.

2 husband owes $500K” (Sunday Herald Article). The article,

written by Katherine Webster, a reporter for the A P , was released

to and published by members of the A P , including the Portsmouth

Herald. The article included statements attributed to Pratt that

concerned Hewson’s appraisal of Douglas & Douglas, the former law

firm of Plaintiff Douglas and his former wife, which was

dissolved on December 3 1 , 1996.

The Sunday Herald article focuses on events involved in the

high profile divorce of Douglas, a former New Hampshire State

Supreme Court Justice and former Member of Congress, from his

former wife, Caroline, an attorney. Hewson prepared an appraisal

of Douglas & Douglas, for use in the divorce proceedings, which

valued the law firm at zero. The report submitted to the court

did not mention $950,211 worth of work pending in the firm, also

referred to as work-in-progress (WIP). The bulk of that figure

consisted of contingency fees the firm might obtain in the

future. In Hewson’s opinion, such contingency fees (paid if the

case is successful but not otherwise) cannot be valued until the

case is complete, and he planned to so testify at trial. The

primary focus of the Sunday Herald article was Mrs. Douglas’s

3 belief that she could not “get a fair divorce in New Hampshire,

because of her husband’s connections and the state’s lack of

safeguards against biased judges” Mrs. Douglas also faulted

Hewson’s appraisal, relied upon by the court in dividing the

marital property in the Douglas’s divorce. Mrs. Douglas is

quoted as saying “I only wonder how may other people in this

state have been hurt by cronyism, fraud and old-boy bias in the

courtroom?” Sunday Herald Article at ¶ 6. The article goes on

to recount the opinions of Mrs. Douglas’s own appraiser, and of

Pratt, regarding the Hewson appraisal report and the judge’s

reliance on i t .

The Douglas divorce trial was set for September 1 5 , 1998.

Mrs. Douglas failed to appear at the trial and the judge refused

to allow her brother, a paralegal who had previously represented

her, to proceed in her absence. Mrs. Douglas was defaulted and a

decree was entered in favor of M r . Douglas. At the time of the

AP article, Mrs. Douglas had appealed the property award,

assigning error to the judge’s refusal to allow her brother to

represent her. She also claimed that Hewson’s opinion – that the

law firm had no value – was incorrect, primarily because the

4 report omitted mention of the $950,211 worth of WIP. Because of

the default, the only valuation evidence presented to the divorce

court was Hewson’s report. Relying on Hewson’s zero valuation of

the couples’ law practice, the trial judge awarded Mrs. Douglas

back pay, but nothing for equity in the practice.

In January or February of 1998, Webster sent Pratt some

information related to Hewson’s appraisal. Mrs. Douglas and her

attorney had also been in contact with Pratt to request his

services in relation to her divorce.2 And, they had been in

contact with Webster. In late February, Pratt, after reviewing

Hewson’s curriculum vitae, wrote to Mrs. Douglas’s attorney. He

stated that Hewson appeared to have no training in business

valuation.

Court orders had been issued in the Douglas divorce

proceedings imposing rules of confidentiality regarding financial

information produced during discovery.

2 The pleadings do not state when this contact took place, other than prior to the publication of the Sunday Herald article.

5 Discussion

Douglas and Hewson allege that Pratt and the AP defamed them

in the article released by the AP and published by, among others,

The Portsmouth Sunday Herald on March 1 5 , 1998. Additionally,

they claim Pratt and the AP were negligent in publishing those

statements. Furthermore, Douglas claims invasion of privacy by

being placed in a false light.

Defendants assert that the statements contained in the March

1 5 , 1998, article are not actionable because they are protected

opinions rather than statements of fact. Defendants also deny

any negligence associated with making the statements or reporting

them. Additionally, Defendants contend that Plaintiff Douglas

cannot maintain a claim for defamation because the allegedly

defamatory statements were not “of and concerning him.” See

Restatement (Second) of Torts, § 564A.

Defamation (Count I )

Plaintiffs point to the latter portion of the Sunday Herald

article and the statements attributed to Pratt as constituting

“[t]he crux of the defamatory ‘sting’.” See Hewson’s Mem. in

6 Opp’n 5 (document n o . 8 3 ) . That portion of the article reads as

follows, with Pratt’s challenged statements underlined:

[T]he main difference between the two appraisals lies in the $950,211 in work in progress.

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