Halliday v. Bd. of Dirs. of the Mental Health & Recovery Bd. of Erie & Ottawa Ctys.

2020 Ohio 702
CourtOhio Court of Appeals
DecidedFebruary 28, 2020
DocketE-19-011
StatusPublished

This text of 2020 Ohio 702 (Halliday v. Bd. of Dirs. of the Mental Health & Recovery Bd. of Erie & Ottawa Ctys.) 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
Halliday v. Bd. of Dirs. of the Mental Health & Recovery Bd. of Erie & Ottawa Ctys., 2020 Ohio 702 (Ohio Ct. App. 2020).

Opinion

[Cite as Halliday v. Bd. of Dirs. of the Mental Health & Recovery Bd. of Erie & Ottawa Ctys., 2020-Ohio-702.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT ERIE COUNTY

Dr. Kirk Halliday Court of Appeals No. E-19-011

Appellant Trial Court No. 2017 CV 0561

v.

The Board of Directors of the Mental Health and Recovery Board of Erie and Ottawa Counties, et al. DECISION AND JUDGMENT

Appellees Decided: February 28, 2020

*****

Peter D. Traska and Michelle L. Traska, for appellant.

Patrick Kasson and Francesca R. Boland, for appellee The Mental Health and Recovery Board of Erie and Ottawa Counties.

James W. Kart, for appellee Firelands Regional Medical Center.

SINGER, J.

{¶ 1} Appellant, Dr. Kirk Halliday, appeals from the February 1, 2019 judgment

of the Erie County Court of Common Pleas, granting the motions for summary judgment of appellees, the Board of Directors of the Mental Health and Recovery Board of Erie and

Ottawa Counties (“Board”), fourteen individual Board members and Firelands Regional

Medical Center (“Firelands”). For the reasons that follow, we affirm.

{¶ 2} Appellant sets forth one assignment of error:

The trial court failed to consider evidence of Appellees’ reasons for

advancing a false narrative concerning the Appellant’s termination as

Executive Director of the Appellee Mental Health and Recovery Board of

Erie and Ottawa Counties.

Background Facts

{¶ 3} Appellant served as the executive director of the Board from 1993 until

November 2016, when the Board suspended him. The Board held an administrative

hearing on March 21, 2017, after which the Board terminated appellant’s employment.

Appellant appealed this decision to the Erie County Court of Common Pleas, case No.

2017 CV 0161. On January 5, 2018, the trial court affirmed the termination. Appellant

appealed to this court and we affirmed the trial court’s judgment. See Halliday v. Mental

Health & Recovery Bd. of Erie & Ottawa Ctys., 6th Dist. Erie No. E-18-005, 2018-Ohio-

4053.

{¶ 4} On November 2, 2017, appellant filed his complaint for defamation/libel

against appellees in Erie County Court of Common Pleas, case No. 2017 CV 0561. In his

complaint, appellant alleged the following. On January 17, 2017, the Board held a

meeting where defamatory statements were made and then published in the Board’s

2. minutes (“FY17 [fiscal year 2017] contract for Firelands Counseling and Recovery

Services [(“FCRS”)] will need to be increased due to incorrect budget allocation

previously given”). On February 21, 2017, the Board held a meeting where defamatory

statements were made and then published in the Board’s minutes (Authorization to

increase FY17 9-month purchase of service contract with FCRS “due to board staff

mathematical error when calculating agency budgets”). In the Fiscal Year 2017 9-Month

Purchase of Service/Grant Contract Amendment-1 and Amendment-2, the Board and

Firelands made defamatory statements (“Whereas the Board desires to increase the

9-Month Purchase of service/Grant Contract due to a mathematical error”). In the Fiscal

Year 9-Month Purchase Wrap/Grant Contract, the Board and Firelands made a

defamatory statement (“Whereas the Board desires to increase the 9-Month Wrap/Grant

Contract due to mathematical error, by Board staff, resulting in an unapproved budget cut

to the provider”).

{¶ 5} Appellant further alleged the defamatory statements denote “budgeting was

done incorrectly, and the mistake was attributed to [appellant] whom the * * * Board

indicated was responsible for ‘the mathematical error’ allegedly causing the budget

error.” Appellant alleged the budgeting was accurate and the math error statement by the

Board and Firelands “was patently false and defamatory, was directed at [appellant]

because he oversaw the budgeting process by staff, and this statement caused him

injuries.”

3. {¶ 6} On November 19, 2018, Firelands filed a motion for summary judgment

asserting there is no evidence the alleged defamatory statements were “of or concerning”

appellant, nor is there clear and convincing evidence that Firelands acted with actual

malice. The Board and its members also filed a motion for summary judgment arguing,

inter alia, there is no evidence the statements were false, the Board and its members are

immune and the Board members did not act recklessly or with malice. On February 1,

2019, the trial court granted the motions for summary judgment. Appellant timely

appealed.

Summary Judgment Standard

{¶ 7} We review a summary judgment decision on a de novo basis. Grafton v.

Ohio Edison Co., 77 Ohio St.3d 102, 105, 671 N.E.2d 241 (1996). Thus, we undertake

an independent examination of the record and make our own decision as to whether the

moving parties are entitled to summary judgment. Dupler v. Mansfield Journal, 64 Ohio

St.2d 116, 119-120, 413 N.E.2d 1187 (1980).

{¶ 8} Summary judgment is appropriate when (1) no genuine issue as to any

material fact exists, (2) the party moving for summary judgment is entitled to judgment

as a matter of law, and (3) viewing the evidence most strongly in favor of the nonmoving

party, reasonable minds can reach only one conclusion, and that is adverse to the

nonmoving party. Civ.R. 56; Harless v. Willis Day Warehousing Co., 54 Ohio St.2d 64,

66, 375 N.E.2d 46 (1978). “The moving party bears the initial responsibility of

informing the trial court of the basis for the motion, and identifying those portions of the

4. record before the trial court which demonstrate the absence of a genuine issue of fact on a

material element of the nonmoving party’s claim.” Dresher v. Burt, 75 Ohio St.3d 280,

292, 662 N.E.2d 264 (1996). Once the moving party meets that burden, the nonmoving

party has a reciprocal burden and “may not rest upon the mere allegations or denials of

the party’s pleadings, but the party’s response, by affidavit or as otherwise provided in

this rule, must set forth specific facts showing that there is a genuine issue for trial.”

Civ.R. 56(E).

Law

{¶ 9} Defamation is a false statement published by a defendant acting with a

degree of fault which injures a person’s reputation, exposes the person to public hatred,

contempt, ridicule, shame or disgrace, or adversely affects the person’s profession.

A & B-Abell Elevator Co. v. Columbus/Cent. Ohio Bldg. & Constr. Trades Council, 73

Ohio St.3d 1, 7, 651 N.E.2d 1283 (1995).

{¶ 10} Statements made about public officials are constitutionally protected when

the statements concern any matter which may touch on the official’s fitness for office.

Soke v. Plain Dealer, 69 Ohio St.3d 395, 397, 632 N.E.2d 1282 (1994). “In order to be

actionable, a plaintiff in a defamation action must show that the alleged defamatory

statement was ‘of and concerning’ the plaintiff.” Whiteside v. United Paramount

Network, 12th Dist. Madison No. CA2003-02-008, 2004-Ohio-800, ¶ 15, citing New York

Times Co. v. Sullivan, 376 U.S. 254, 267, 84 S.Ct.

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New York Times Co. v. Sullivan
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591 N.E.2d 789 (Ohio Court of Appeals, 1990)
Early v. the Toledo Blade
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Harless v. Willis Day Warehousing Co.
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Dupler v. Mansfield Journal Co.
413 N.E.2d 1187 (Ohio Supreme Court, 1980)
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2020 Ohio 702, Counsel Stack Legal Research, https://law.counselstack.com/opinion/halliday-v-bd-of-dirs-of-the-mental-health-recovery-bd-of-erie-ohioctapp-2020.