Joseph E. Hancock v. Easwaran P. Variyam

CourtCourt of Appeals of Texas
DecidedJune 16, 2011
Docket07-09-00277-CV
StatusPublished

This text of Joseph E. Hancock v. Easwaran P. Variyam (Joseph E. Hancock v. Easwaran P. Variyam) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph E. Hancock v. Easwaran P. Variyam, (Tex. Ct. App. 2011).

Opinion

NO. 07-09-0277-CV

IN THE COURT OF APPEALS

FOR THE SEVENTH DISTRICT OF TEXAS

AT AMARILLO

PANEL C

JUNE 16, 2011

JOSEPH E. HANCOCK, APPELLANT

v.

EASWARAN P. VARIYAM, APPELLEE

FROM THE 99TH DISTRICT COURT OF LUBBOCK COUNTY;

NO. 2006-537,571; HONORABLE WILLIAM C. SOWDER, JUDGE

Before QUINN, C.J., HANCOCK and PIRTLE, JJ.1

OPINION

Appellant, Joseph E. Hancock, appeals from a judgment entered in a defamation

action in favor of Appellee, Easwaran P. Variyam, following a jury trial. In support,

Hancock presents three issues: (1) whether the trial court erred in finding as a matter of

law that Hancock's written statements were libel per se; (2) whether Variyam's evidence

1 For purposes of disclosure, we note that Justice Hancock is not related to Appellant. of damages is legally and factually insufficient; and (3) whether the trial court erred in

admitting an anonymous letter at trial. We affirm.

Background

At all relevant times, Hancock and Variyam were physicians practicing internal

medicine and gastroenterology at the Texas Tech University Medical Center in

Lubbock, Texas. Both men were on the faculty of Texas Tech. Variyam was formerly

the Chief of the Gastroenterology Division from September 2000 until January 2006,

and as such, he was Hancock's supervisor when the following events occurred.

On the morning of January 2, 2006, a dispute arose between the two physicians

related to the transfer of patients from Hancock's care to Variyam's care. After Variyam

wrote a letter to Hancock alleging he had disregarded patient care, Hancock responded

with a letter of resignation wherein he stated, in pertinent part, as follows:

Please find a copy of letter from Dr Variyam letter (sic) which I received today. Due to Dr Variyam's reputation for lack of veracity, a majority of my communications and interactions is (sic) recorded or witnessed and subsequently verified as in this case. My telephone conversation was over the speakerphone and witnessed by a third party who will dispute Dr. Variyam's position. The interaction by and through the Department of Internal Medicine this morning is again refutable. Dr Variyam deals in half truths, which legally is the same as a lie. It is Dr. Variyam's ethical behavior that should be challenged.

Hancock addressed his letter to Bernhard Mittemeyer, Dean of the School of

Medicine, and copied Donald Wesson, Chair of Internal Medicine, David Hodges,

Associate Professor and Director of the UMC Endoscopy Center, Variyam and the 2 Accreditation Council for Graduate Medical Education (ACGME) in Chicago, Illinois.2 In

February of 2006, Variyam was removed as Chief of the Gastroenterology Division.

In December 2006, Variyam filed an original petition alleging that Hancock's letter

had defamed him. Variyam sought special damages for loss of past and future income

as well as general damages for injury to his reputation and mental anguish. He also

sought exemplary damages. In November 2008, Variyam and Hancock filed an agreed

order wherein Variyam agreed to forego special damages arising out of his removal as

Chief of the Gastroenterology Division, but retained his defamation claim under a per se

theory. Hancock continued to assert truth as an affirmative defense.

In May 2009, a three day jury trial was held. At its conclusion, the trial court

found that the statements in Hancock's letter were libel per se. The jury rejected

Hancock's affirmative defense by finding that his statements3 regarding Variyam were

not substantially true at the time they were made and that, by clear and convincing

evidence, the harm to Variyam resulted from malice on Hancock's part. The jury

2 At all times relevant to this case, Hancock knew that ACGME was an independent organization that accredits institutions where medical training takes place nationwide. When Hancock wrote his letter, he was aware that an application for reinstatement of Texas Tech's Gastroenterology Fellowship was pending with ACGME and that Texas Tech and ACGME were scheduled to meet toward the end of January 2006 to decide the fate of Texas Tech's Fellowship Program of which Variyam was the Program Director. Hancock was also aware that the letter would be received by ACGME's Residency Review Committee, a committee comprised of physicians who were national experts in the field of gastroenterology or internal medicine. In addition to Hancock's letter, ACGME received an anonymous letter dated January 19 complaining about two doctors, Farooq and Parupudi, participants in the gastroenterology training program. 3 From the Charge of the Court, question 1 addressed the statement "reputation for lack of veracity"; whereas, question 2 addressed the statement "deals in half truths, which is legally the same as a lie."

3 awarded Variyam actual damages of $90,0004 and exemplary damages of $85,000.

Variyam was also awarded prejudgment interest of $6,455.68 and court costs. This

appeal followed.

Discussion

Hancock contends the trial court erred by finding, as a matter of law, that his

statements were libel per se because the statements were ambiguous and did not injure

Variyam in his office or occupation as a physician. He also asserts that the evidence is

legally and factually insufficient to justify any award for mental anguish or injury to

reputation. He contends Variyam failed to prove that Hancock's statements caused him

any damage and, alternatively, that the trial court erred by not issuing a jury instruction

on proximate cause. Lastly, he asserts the trial court erred by admitting an anonymous

letter at trial.

Issue One - Libel per se

Defamation is generally defined as the invasion of a person's interest in his or her

reputation and good name. Prosser & Keeton on Torts § 111, at 771 (5th ed. 1984 &

Supp. 1988). Defamation claims are divided into two categories depending on how the

defamatory statement was communicated: libel for written communications and slander

for oral communications.5

4 The jury awarded Variyam $30,000 for loss of reputation in the past, $30,000 for future loss of reputation, $15,000 for past mental anguish and $15,000 for future mental anguish. 5 Libel is defined by statute as "defamation expressed in written or other graphic form that tends to . . . injure a living person's reputation and thereby expose the person to . . . financial injury or to impeach any person's honesty, integrity, virtue, or reputation . . . ." Tex. Civ. Prac. & Rem. Code Ann. § 73.001 (West 4 Defamation claims are also divided into two categories, defamation per se and

defamation per quod, according to the level of proof required in order to make them

actionable. Texas Disposal Sys. Landfill, Inc. v. Waste Mgmt. Holdings, Inc., 219

S.W.3d 563, 580 (Tex.App.--Austin 2007, pet. denied); Moore v. Waldrop, 166 S.W.3d

380, 384 (Tex.App.--Waco 2005, no pet.). Statements that are defamatory per quod are

actionable only upon allegation and proof of damages. Texas Disposal, 219 S.W.3d at

580; Alaniz v. Hoyt, 105 S.W.3d 330, 345 (Tex.App.--Corpus Christi 2003, no pet.).

That is, before a plaintiff can recover for defamation per quod, he must carry his burden

of proof as to both the defamatory nature of the statement and the amount of damages

caused by the publication of that statement.

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