Hoid v. Fox 31

CourtColorado Court of Appeals
DecidedMay 15, 2025
Docket24CA1229
StatusUnpublished

This text of Hoid v. Fox 31 (Hoid v. Fox 31) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hoid v. Fox 31, (Colo. Ct. App. 2025).

Opinion

24CA1229 Hoid v Fox 31 05-15-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA1229 City and County of Denver District Court No. 23CV558 Honorable Mark T. Bailey, Judge

Edward Hoid,

Plaintiff-Appellant,

v.

FOX-31 News and Byron Grandy, General Manager,

Defendants-Appellees.

JUDGMENT AFFIRMED AND CASE REMANDED WITH DIRECTIONS

Division VII Opinion by JUDGE JOHNSON Lipinsky and Moultrie, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 15, 2025

Edward Hoid, Pro Se

Ballard Spahr, LLP, Ashley I. Kissinger, Denver, Colorado; Ballard Spahr, LLP, Kennison Lay, Phoenix, Arizona, for Defendants-Appellees ¶1 Plaintiff, Edward Herbert Hoid (Hoid), appeals the district

court’s judgment dismissing his lawsuit against defendant, FOX-31

News (FOX-31). On appeal, Hoid contends that (1) his defamation

and defamation-related claims are not barred by the statute of

limitations because they did not accrue until a later date than the

one identified by the court or the limitation period should be

extended through equitable tolling; (2) the district court erred by

applying Colorado’s anti-SLAPP statute, section 13-20-1101, C.R.S.

2024, to his lawsuit;1 and (3) the district court committed judicial

misconduct by aiding FOX-31’s concealment of its defamatory

publications.

¶2 Even if the anti-SLAPP statute did not apply to Hoid’s lawsuit,

his claims fail as a matter of law because they are time barred. But

because we agree with the district court that the anti-SLAPP statute

applies, and we agree that the court properly granted FOX-31’s

special motion to dismiss, we remand the case to the district court

1 SLAPP stands for “strategic lawsuits against public participation.”

Creekside Endodontics, LLC v. Sullivan, 2022 COA 145, ¶ 1 n.1.

1 to determine and award FOX-31 its reasonable attorney fees and

costs, including those incurred on appeal.2

I. Background

¶3 On November 5, 2020, a seventy-one-year-old man (the victim)

was found on a biking trail in Longmont suffering from injuries that

later led to his death. The Longmont Public Safety Department (the

police) investigated and discovered that the victim had been

knocked off his bicycle and robbed of his phone, wallet, credit

cards, and bicycle.

¶4 The police issued press releases from November 21, 2020, to

November 27, 2020, notifying the public concerning its

investigation. Based on the press releases, FOX-31, a Denver

television station, published three articles and one report

(collectively, the news articles) on its website updating the public

regarding the investigation. The news articles identified Hoid as a

person of interest “possibly connected to” the victim’s death, but at

2 Hoid named Bryon Grandy (Grandy), the general manager for

FOX-31, as a codefendant. Although Hoid asserts no allegations against Grandy in this appeal, our affirmance of the district court’s order also applies to him.

2 no time did they implicitly or explicitly state that Hoid had been

charged in the victim’s death.

¶5 On November 27, 2020, the police arrested Hoid and charged

him with various criminal offenses, including identity theft for

allegedly using the victim’s credit card. Hoid was not criminally

charged in connection with the victim’s death. Hoid pled guilty to

several criminal offenses and was sentenced to seven years in the

custody of the Department of Corrections.3

¶6 On September 8, 2023, Hoid filed this lawsuit against FOX-31,

asserting that FOX-31’s statements in the news articles created

public scrutiny that harmed his reputation and placed his family in

danger. He asserted claims of defamation, child

endangerment/abuse, public endangerment, false light, and

discrimination.

3 Following Hoid’s conviction, he filed a motion for postconviction

relief under Crim. P. 35. We take judicial notice of Hoid’s appeal in which a division of this court affirmed the postconviction court’s summary denial of Hoid’s request for relief. See People v. Hoid, (Colo. App. No. 23CA1976, Dec. 19, 2024) (not published pursuant to C.A.R. 35(e)); see also People v. Sa’ra, 117 P.3d 51, 56 (Colo. App. 2004) (“A court may take judicial notice of the contents of court records in a related proceeding.”).

3 ¶7 FOX-31 filed a special motion to dismiss, arguing that Hoid’s

defamation claim was subject to the anti-SLAPP statute, as were his

other claims because they related to the defamation claim. FOX-31

contended that Hoid’s defamation claim failed because he could not

prove that FOX-31 acted with actual malice when it made the

statements, or alternatively, Hoid’s claim was barred by the statute

of limitations. At a hearing on FOX-31’s motion, Hoid alleged that

the news station had not disclosed all its broadcast stories about

him. FOX-31 submitted to the court a copy of another television

broadcast.

¶8 The district court granted FOX-31’s special motion to dismiss,

entering a written order that found (1) Hoid’s defamation and

defamation-related claims were barred by the applicable one-year

statute of limitations, and (2) Hoid was not likely to succeed on the

merits of his claims because he could not prove that FOX-31 acted

with actual malice when it published the statements.

II. Statute of Limitations

¶9 We conclude, as did the district court, that Hoid’s claims all

stem from or are derivative of his defamation claim.

4 A. Standard of Review and Applicable Law

¶ 10 We review de novo when a claim accrues under a statute of

limitations. Rider v. State Farm Mut. Auto. Ins. Co., 205 P.3d 519,

521 (Colo. App. 2009). But whether the statute of limitations bars a

particular claim because a court finds certain circumstances is

generally a question of fact. Sulca v. Allstate Ins. Co., 77 P.3d 897,

899 (Colo. App. 2003).

¶ 11 In Colorado, defamation claims are subject to a one-year

statute of limitations. See § 13-80-103(1)(a), C.R.S. 2024 (the one-

year period applies for “[t]he following tort actions: Assault, battery,

false imprisonment, false arrest, libel, and slander”). A defamation

claim “accrues on the date both the injury and its cause are known

or should have been known by the exercise of reasonable diligence.”

Burke v. Greene, 963 P.2d 1119, 1121 (Colo. App. 1998); Taylor v.

Goldsmith, 870 P.2d 1264, 1266 (Colo. App. 1994).

B. Accrual Date

¶ 12 The district court determined that Hoid’s defamation claim

accrued in November 2020 and, thus, his lawsuit was filed outside

the one-year limitation period found in section 13-80-103(1)(a). It

reasoned that Hoid knew, or should have known through

5 reasonable diligence, about FOX-31’s statements, based on

allegations he asserted in the federal case he filed in March 2023

against FOX-31, captioned Hoid v. FOX-31 News, No. 23-cv-00670

(D. Colo. [dismissed] Aug. 2023) (the federal case).

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