Jacobs v. Sandusky Register

2024 Ohio 5422, 257 N.E.3d 1149
Ohio Court of Appeals·Decided November 15, 2024·No. E-24-006·Published·Cited by 1 cases

Opinion

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT

ERIE COUNTY

Matthew Jacobs Court of Appeals No. E-24-006

Appellant Trial Court No. 2022 CV 0097

v. Sandusky Register, et al. DECISION AND JUDGMENT Appellees Decided: November 15, 2024

*****

Richard M. Kerger, for appellant.

David L. Marburger, for appellee.

*****

MAYLE, J.

{¶ 1} Plaintiff-appellant, Matthew Jacobs, appeals the January 2, 2024 judgment of the Erie County Court of Common Pleas, granting summary judgment in favor of defendants-appellees, Matt Westerhold, and Ogden News Publishing of Ohio, Inc. (aka the Sandusky Register) (collectively, “the defendants”). For the following reasons, we affirm the trial court judgment.

{¶ 2} Also before the court is Jacob’s motion to supplement the record with the transcript of the deposition of Matt Westerhold. Jacobs cited the deposition transcript in his brief opposing summary judgment, but according to the trial court docket, did not file the transcript or excerpts of the transcript in the trial court. For the reasons described below, we deny Jacob’s motion.

II. Background

{¶ 3} Matthew Jacobs is the sole detective for the city of Huron and was a part-

time wrestling coach for Huron City Schools. Ogden News Publishing of Ohio, Inc. owns the Sandusky Register newspaper, and Matt Westerhold is the paper’s managing editor.

{¶ 4} Jacobs filed a complaint for libel against Ogden, the Sandusky Register, and Westerhold. According to Jacobs’s complaint, in the spring of 2019, two 13-year-old girls (Jane Doe 1 and Jane Doe 2) alleged that a male classmate (John Doe) sent them photos of penises. Jane Doe 1’s father contacted Jacobs for advice how to handle the incident. Jacobs told him they could (1) file a criminal complaint, or (2) try to resolve the matter with John Doe’s family. Jane Doe 1’s father told Jacobs that he would attempt the second option. Jacobs became concerned that Jane Doe’s family could be subject to criminal sanctions if these photos remained on the girl’s phone, so he told Jane Doe 1’s father that if they elected not to pursue criminal charges, they should destroy the photographs.

{¶ 5} Soon after speaking with Jane Doe 1’s father, Jane Doe 2’s parents contacted Jacobs and said that they wished to pursue a criminal complaint. He told them that they should come in to file the report. At some point, Jacobs told both families that he coaches John Doe and knows his family, but he assured them that he could be fair and impartial in handling the matter. He alleged that neither family objected.

{¶ 6} Jacobs claimed in his complaint that he thoroughly investigated the girls’

accusations, conducted interviews, reviewed the photographs, and with the recommendation of the police chief, turned the investigation over to the Erie County Juvenile Prosecutor, who filed charges. While the matter was being investigated, new charges surfaced that John Doe had nonconsensual sexual contact with one of the girls. Jacobs investigated a possible charge for gross sexual imposition, but he did not file the charge because he concluded that no probable cause existed. The prosecutor disagreed and a new complaint was filed. John Doe eventually entered into a plea agreement.

{¶ 7} While these issues were developing, news stories were published in the Sandusky Register. Jacobs alleged that Westerhold was “unrelenting in his efforts to obtain and report information.” He claimed that Westerhold obtained a copy of the investigation “that contained answers to many of the questions which were being presented in the Defendant Newspaper as unanswered,” but “no effort was made to furnish those answers in any news article.” Instead, Jacobs alleged, the newspaper repeatedly reported the allegations contained in civil suits filed by the families and printed that Jacobs had “mishandled” the investigation “despite the fact that no one was ever able to point to any way in which that had occurred.” Jacobs claimed that on August 15, 2021, the defendants “made the statement of fact that [Jacobs] had mishandled the investigation”—a statement that Jacobs claimed was false. He alleged that the false statement constituted libel per se because the statement damaged him professionally.

{¶ 8} The defendants moved to dismiss the claim. The trial court denied the motion, and an answer was filed. The defendants later filed a motion for summary judgment, attaching the Jane Doe families’ complaints and the August 15, 2021 article referenced by Jacobs.

{¶ 9} The defendants argued that R.C. 2317.05—Ohio’s statutory fair report privilege—protects press accounts that summarize allegations in civil pleadings where the account is impartial and substantially accurate and it was not published maliciously. They maintained that the privilege protects the newspaper article at issue here. They also claimed that the challenged statement—summarizing the Jane Doe families’ allegations as claiming that Jacobs “mishandled” the investigation—was an expression of an opinion and was inactionable.

{¶ 10} Jacobs sought a continuance under Civ.R. 56(F) so that he could conduct additional discovery. He ultimately deposed Westerhold, then filed his brief in opposition to the motion for summary judgment.

{¶ 11} Jacobs recognized that “statements in civil pleadings have an absolute privilege,” and “under the litigation privilege doctrine, a newspaper publishing [a report about a civil suit] has no liability, at least according to the Defendant.” He conceded that the statements were not published maliciously. But Jacobs argued that the defendants did not act impartially when they published the August 15, 2021 article, given that the newspaper interviewed the Jane Doe families but not Jacobs. He disagreed that the article reported the defendants’ opinions, and maintained that the article did not merely quote the civil complaint, but instead asserted as fact that Jacobs had mishandled the investigation.

{¶ 12} In support of his position, Jacobs pointed to Westerhold’s deposition testimony where he explained that the paper publishes editorials when it has an opinion about a problem in the community warranting the newspaper’s attention, and denied that the newspaper had an obligation to determine the accuracy of an allegation in a lawsuit before reporting it. Westerhold testified that he never met Jacobs, did not interview him or ask any reporter to do so, had no reason for not interviewing him, and did not know that statements contained in civil litigation are absolutely privileged. He said that he assumed that the police chief knew he could call Westerhold, the editorial board did not discuss whether the families’ concerns were valid, and he believed that if someone said something in a lawsuit, he could report it without checking to be sure that it is accurate.

{¶ 13} Jacobs responded in his opposition brief that John Doe’s family initiated a lawsuit against the newspaper, and as part of the settlement of that action, the newspaper agreed to withdraw from its website 15 articles, listed in an exhibit that was used at Westerhold’s deposition. Westerhold testified that he did not know the context of the agreement to withdraw the articles, but he agreed that it is unusual for stories to be withdrawn.

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Jacobs v. Sandusky Register, 2024 Ohio 5422, 257 N.E.3d 1149 (Ohio Ct. App. 2024).

2024 Ohio 5422 (Jacobs v. Sandusky Register) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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