John J. Ryan v. John Brooks, and Harper & Row Publishers, Inc., John J. Ryan v. John Brooks, and Harper & Row Publishers, Inc.

634 F.2d 726, 6 Media L. Rep. (BNA) 2155, 1980 U.S. App. LEXIS 13046
CourtCourt of Appeals for the Fourth Circuit
DecidedOctober 17, 1980
Docket79-1473, 79-1474
StatusPublished
Cited by45 cases

This text of 634 F.2d 726 (John J. Ryan v. John Brooks, and Harper & Row Publishers, Inc., John J. Ryan v. John Brooks, and Harper & Row Publishers, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John J. Ryan v. John Brooks, and Harper & Row Publishers, Inc., John J. Ryan v. John Brooks, and Harper & Row Publishers, Inc., 634 F.2d 726, 6 Media L. Rep. (BNA) 2155, 1980 U.S. App. LEXIS 13046 (4th Cir. 1980).

Opinion

JAMES DICKSON PHILLIPS, Circuit Judge:

This appeal arises from an action for libel brought by John J. Ryan, former Vice-President and General Manager for North Carolina of Southern Bell Telephone Company. Ryan claimed that he had been libelled in a book written by defendant John Brooks and published by defendant Harper & Row in February 1976. Entitled Telephone: The First Hundred Years, the book was commissioned by AT&T as a corporate history to be published during the centennial year of the telephone’s existence. Only one sentence of the 345-page volume mentioned Ryan; it purported to summarize Ryan’s account, released to the press in January 1975, of Southern Bell’s political activities during his tenure. Ryan took issue with Brooks’ choice of words in that sentence; and a federal jury agreed that the sentence was false and defamatory of Ryan. They awarded him $5,000 actual and $150,000 punitive damages, against Brooks and Harper & Row jointly. Defendants raise several issues on this appeal, including a thorny question of the correct statute of limitations to be applied under controlling North Carolina law. 1 But we find one issue dispositive, and reach only that: whether there was sufficient evidence that the defendants published the allegedly defamato *728 ry matter with “actual malice” under the standard of New York Times v. Sullivan, 376 U.S. 254, 84 S.Ct. 710, 11 L.Ed.2d 686 (1964). 2 Upon our own careful review of the evidence, see id. at 285, 84 S.Ct. at 728, we conclude that there was insufficient evidence of malice to sustain a judgment against defendants, while affording them the full protection required by the First Amendment. We therefore reverse the judgment and remand with instructions to enter judgment n. o. v. for defendants.

I

Before reaching the dispositive questions of law, a fuller discussion of the factual background of this case is necessary. John Ryan held the North Carolina Vice-President position for Southern Bell from 1964 to 1973, when higher-ups asked him to retire. In late 1974, rumors of corruption at a high level of the Southern Bell operation began to circulate, sparked by news of the suicide of the Texas Vice-President of Southwestern Bell and his suicide note detailing charges of illegal political contributions and wiretapping by the company. Ryan testified that he was immediately contacted by newspaper reporters in Charlotte, N.C., who were investigating the possible existence of similar political activity in Southern Bell’s Charlotte headquarters. At first he refused to talk with them, but soon became concerned when it appeared that Charlotte Observer reporters were getting information from other Southern Bell sources that Ryan had operated a political “slush fund” out of his Charlotte office, funded by proceeds from false expense vouchers. Fearing that he would be made to appear the scapegoat in forthcoming news stories that would not accurately describe Southern Bell’s political fund and his role in operating it, Ryan decided to go on record about the fund.

In the interview with Observer reporters Marion Ellis and Howard Covington, published in a copyrighted article on January 15, 1975, and in his testimony at the trial below, Ryan described the operation of Bell’s political fund as follows. Each Southern Bell department head, upon his promotion to that position, was informed that he would receive a $2,500 annual raise, but that the money was not his; it was to be paid back to the company’s political fund in cash payments of $100 a month. Ryan testified that as it was explained to him when he became a department head, he had the option to decline the raise, but if he took it, he was “committed permanently” to the $100 a month payments. In addition to the inevitable pressure that a rising corporate executive would feel to accept the raise and not appear to be unwilling to do his part for the company, there was a positive incentive. The company increased the raise by the amount of extra income tax that would be owed, and the total increase resulted in a larger salary base and thus a larger pension upon retirement. No department head, to Ryan’s knowledge, had ever refused this “raise.”

As director of Bell’s North Carolina operation, Ryan collected the salary kickbacks from the eight or nine department heads under him, and gave it out in cash to state political candidates of both parties, in hopes that Bell would have the ear of whoever was elected. In 1972, the peak year for this activity, Ryan said that he contributed a total of $28,000 to candidates for governor, senator and congressman in North Carolina. Ryan’s story made headlines in the Observer on January 15, 1975, and related articles received extensive coverage over a wide area for some months thereafter.

At about this time, John Brooks, an experienced writer about business matters, was working under contract to AT&T and Harper & Row on the book Telephone. He learned of Ryan’s allegations through several secondary sources, and felt they should *729 be included in a section discussing recent scandals within the corporation. Brooks summarized the Ryan story in the following sentence found on page 310 of the published volume:

But in January 1975, John J. Ryan, a former vice-president for Southern Bell Telephone Company in charge of service for North Carolina, who had been forced to retire in June 1973 on grounds of “unsatisfactory performance”, said in a series of local newspaper interviews that over a period of years he had made political contributions to candidates who were expected to be favorable to the interests of Southern Bell, deriving the funds from salary kickbacks extorted from leading Southern Bell executives that had been concealed by the use of false vouchers.

The book Telephone was published in February 1976. By May 1977, its one hardcover and two paperback editions had sold approximately 195,000 copies, of which AT&T had purchased 150,000, and the company’s stockholders 30,000 through a coupon purchasing plan.

Ryan first learned about the statement when he read a book review of Telephone by Marion Ellis in the Observer. Ellis pointed out that the book contained “one major error,” in that Ryan “has never acknowledged the existence of a bogus voucher scheme.” After reading the book, Ryan engaged counsel and demanded that Harper & Row retract the statement. He particularly objected to the use of the word “extorted,” and to the mention of a false voucher plan for concealment of the kickbacks. Harper & Row and Brooks did eventually agree to change the statement about Ryan, 3 but the new version could not be inserted until the second paperback edition was issued in August 1976. The publishers refused Ryan’s demand to delete all mention of him from the book, however, and he filed the complaint that began this suit on May 2, 1977. He named AT&T, Harper & Row, and Brooks as defendants, but AT&T settled before trial and the case proceeded against the publisher and author.

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634 F.2d 726, 6 Media L. Rep. (BNA) 2155, 1980 U.S. App. LEXIS 13046, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-j-ryan-v-john-brooks-and-harper-row-publishers-inc-john-j-ca4-1980.