Kenney v. Howard

CourtSuperior Court of Maine
DecidedSeptember 22, 2004
DocketCUMcv-03-656
StatusUnpublished

This text of Kenney v. Howard (Kenney v. Howard) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kenney v. Howard, (Me. Super. Ct. 2004).

Opinion

STATE OF MAINE Ce ee SUPERIOR COURT

CUMBERLAND, ss. ' CIVIL ACTION . Se DOCKET NO. CV-03, 6; REC- oi Vans. MATTHEW KENNEY, wt ve 2% ek 4G i Plaintiff Vv. ORDER ON DEFENDANTS’ MOTION TO DISMISS

MANNY HOWARD, BRIAN KEMPNER THE NEW YORK OBSERVER, LP. and

NEW YORK OBSERVER, INC. Defendants. NOV: ony FACTUAL BACKGROUND

Plaintiff is a prominent chef who has owned numerous restaurants in New York and Maine. This case stems from a newspaper article (“the article”) written by Defendant Manny Howard and published in the New York Observer newspaper (“the Observer”) on February 18, 2002. The article focused on the plaintiff's business enterprises in New York and, more specifically, discussed his alleged financial woes as evidenced by various tax liens Mr. Howard claimed had been assessed against the plaintiff's businesses for nonpayment of payroll and sales taxes. In addition, the article suggested that the plaintiff’s debt was the result of expensive living and a lack of entrepreneurial know-how. Plaintiff claims that the details of the article were inaccurate, exaggerated and suggested that he was in greater financial distress than he was.

In addition to the hard copy circulation of the newspaper, the Observer maintains a website on which it publishes its newspaper. The article appeared on the Observer’s website in the February 18, 2002 edition of the newspaper. Additionally, while the Observer is primarily a New York-based publication, it is read by an international audience as a result of subscriptions and the Internet. There are

approximately 100 holders of subscriptions to the Observer in Maine. In his complaint, Plaintiff alleges that three Maine newspapers, the Portland Press Herald/Maine Sunday Telegram, the Portland Phoenix and the Casco Bay Weekly (“the Maine newspapers”), published excerpts of the article because of plaintiffs two businesses in Maine — the Market Restaurant, LLC and the Searsport Tavern, LLC. Market Restaurant, LLC operated as the Market Restaurant in Portland, Maine from November 2000 until April 2002 when it closed. Searsport Tavern, LLC was to operate as Nickerson Tavern in Searsport, Maine but that restaurant never opened.

On February 21, 2003, more than one year after the article was published, the plaintiff filed a complaint in the New York Supreme Court against Manny Howard and. the Observer, claiming defamation and tortious interference with economic advantage (“the New York action”). On September 10, 2003, that court granted the defendants’ motion to dismiss, finding that (1) New York’s one-year statute of limitation for defamation claims had run; and (2) his tortious interference with economic advantage claims were “not viable because they are not based upon the interference with any contract or business relationship distinct from the general declaration of injury to reputation included in the defamation claim.” Kenney v. Howard et al., Index No. 103018/03 (N.Y. Gen. Term 2003). That court also denied the plaintiff's cross motion seeking to compel the court to apply Maine’s two-year statute of limitations, finding that “plaintiff's claims are subject to New York’s statute of limitations because they stem from acts performed solely,” in New York. Id.

On November 26, 2003 the plaintiff filed his complaint in the instant action with this court (“the Maine action”). Plaintiff claims that this court has jurisdiction because, as a dual resident of Maine and New York, he is a resident of Maine and has suffered harm here as a result of the article having been “picked up,” and published in Maine newspapers. He also claims that he suffered harm in Maine when defendant Observer

distributed the article to Maine subscription-holders. As in the New York action, his

9 complaint in the Maine action names as defendants Manny Howard and the Observer. In addition, he has also named Brian Kempner, President and general counsel for the Observer, individually. Plaintiff’s original complaint in this court alleges defamation and tortious interference. With regard to the defendant Brian Kempner, plaintiff alleges that Mr. Kempner is liable for defamation because he “approved” the article prior to publication. The plaintiff has also filed a motion seeking to amend the original complaint in order to add claims for (1) intentional Infliction of Emotional Distress (“ITED”); (2) Negligent Infliction of Emotional Distress (“NIED”); (3) Slander (against Defendant Howard only); and (4) False Light. Plaintiff's motion to amend also seeks to add as co-plaintiffs the two restaurants he owns in Maine: Searsport Tavern, LLC and Market Restaurant, LLC.

The defendants have moved to dismiss the complaint arguing that: (1) under Maine’s Borrowing Statute, 14 M.R.S.A. § 866, the plaintiff may not relitigate claims in Maine that have already been barred by the running of New York’s statute of limitations; (2) plaintiff is barred under the doctrine of res judicata, because a final judgment was entered in the New York action brought by the plaintiff on the same theories and against the same defendants, or their privies; (3) the defendants lack the requisite minimum contacts with Maine sufficient to confer personal jurisdiction upon this court; and (4) with respect to Defendant Kempner, plaintiff's contention that an attorney may be held liable for pre-publication “approval” of an allegedly defamatory argument fails to state a claim for which relief can be granted and should be dismissed pursuant to MLR. Civ. P. 12(b)(6).

DISCUSSION

1. Plaintiff's Motion to Amend the Complaint

By moving to amend his complaint, plaintiff seeks to add the Maine restaurants

as plaintiffs and add several new bases for recovery against the defendants. Defendants

2 have opposed the motion, arguing that the proposed amendment would fail to state any claims for which relief could be granted and that it would therefore be futile.

Under Maine law, a motion to amend may be denied where the amended complaint would be futile. Glynn v. City of S. Portland, 640 A.2d 1065, 1067 (Me. 1994). “Futility” means that the complaint, as amended, would fail to state a claim upon which relief could be granted.” Glassman v. Computervision Corp., 90 F.3d 617, 623 (1st Cir. 1996). In reviewing for "futility," a trial court “applies the same standard of legal sufficiency as applies to a Rule 12(b)(6) motion.” Id. Under MR. Civ. P. 12(b)(6), "[a] dismissal should only occur when it appears ‘beyond doubt that a plaintiff is entitled to no relief under any set of facts that he might prove in support of his claim." McAfee v. Cole, 637 A.2d 463, 465 (Me. 1994) (quoting Hall v. Bd. of Envtl. Prot., 498 A.2d 260, 266 (Me. 1985)).

a. Adding the Maine Restaurants as Plaintiffs

With regard to the plaintiffs motion to add the Maine restaurants as parties, the defendants have argued that the defamation claim they would be asserting must fail as amatter of law. The court agrees. In Maine, defamation consists of:

(a) a false and defamatory statement concerning another; (b) an

unprivileged publication to a third party; (c) fault amounting at least to

negligence on the part of the publisher; and (d) either actionability of the

statement irrespective of special harm or the existence of special harm

caused by the publication. Rice v. Alley, 2002 ME 43, [ 19, 791 A.2d 932, 936 (quoting Lester v. Powers,

Related

Gonzalez Abreau v. Banco Central
27 F.3d 751 (First Circuit, 1994)
Glassman v. Computervision Corp.
90 F.3d 617 (First Circuit, 1996)
Dynamic Image Technologies, Inc. v. United States
221 F.3d 34 (First Circuit, 2000)
Moody v. State Liquor & Lottery Commission
2004 ME 20 (Supreme Judicial Court of Maine, 2004)
Glynn v. City of South Portland
640 A.2d 1065 (Supreme Judicial Court of Maine, 1994)
Levasseur v. Aaron
503 A.2d 1291 (Supreme Judicial Court of Maine, 1986)
Tyson v. Whitaker & Son, Inc.
407 A.2d 1 (Supreme Judicial Court of Maine, 1979)
McAfee v. Cole
637 A.2d 463 (Supreme Judicial Court of Maine, 1994)
Rice v. Alley
2002 ME 43 (Supreme Judicial Court of Maine, 2002)
Rutland v. Mullen
2002 ME 98 (Supreme Judicial Court of Maine, 2002)
Marston v. Newavom
629 A.2d 587 (Supreme Judicial Court of Maine, 1993)
Cole v. Chandler
2000 ME 104 (Supreme Judicial Court of Maine, 2000)
Hall v. Board of Environmental Protection
498 A.2d 260 (Supreme Judicial Court of Maine, 1985)
Kradoska v. Kipp
397 A.2d 562 (Supreme Judicial Court of Maine, 1979)
Lester v. Powers
596 A.2d 65 (Supreme Judicial Court of Maine, 1991)
Vahlsing Christina Corp. v. Stanley
487 A.2d 264 (Supreme Judicial Court of Maine, 1985)
Johanson v. Dunnington
2001 ME 169 (Supreme Judicial Court of Maine, 2001)

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