Knight v. Chicago Tribune Company

CourtAppellate Court of Illinois
DecidedSeptember 10, 2008
Docket1-06-0957 Rel
StatusPublished

This text of Knight v. Chicago Tribune Company (Knight v. Chicago Tribune Company) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Knight v. Chicago Tribune Company, (Ill. Ct. App. 2008).

Opinion

THIRD DIVISION SEPTEMBER 10, 2008

No. 1-06-0957

THOMAS L. KNIGHT, ) Appeal from the Circuit Court ) of Cook County, Illinois. Plaintiff-Appellant, ) ) v. ) No. 00 L 4988 ) CHICAGO TRIBUNE COMPANY, a Corporation,) MAURICE POSSLEY and KEN ARMSTRONG, ) Honorable Robert E. Gordon, ) Judge Presiding. Defendants-Appellees. )

PRESIDING JUSTICE MURPHY delivered the opinion of the court:

This defamation action involves a trial about a trial about a trial. Thomas Knight was an

assistant State's Attorney who prosecuted Rolando Cruz for the murder of Jeanine Nicarico.

Eventually the court acquitted Cruz. Other prosecutors later charged Knight with obstruction of

justice. Knight also won an acquittal. Knight then sued Maurice Possley and his employer, the

Chicago Tribune, accusing them of publishing falsehoods in their article about the prosecution

against Knight on the charge of obstructing justice. The jurors found factual inaccuracies in the

article. However, in response to a special interrogatory, they found that Knight failed to prove,

by clear and convincing evidence, that Possley acted with actual malice. The trial court entered

judgment in favor of defendants based on the general verdict supported by the special finding. 1-06-0957

On appeal Knight argues that the court instructed the jury erroneously on damages and

erroneously admitted evidence of other negative publicity about Knight. Knight also contends

that defense counsel's closing remarks deprived him of a fair trial. We find that the court's

rulings, sustaining objections to the remarks at issue, cured any such error. Any errors in the

admission of evidence on damages and the damages instructions had no effect on the dispositive

finding that Knight failed to prove actual malice. Accordingly, we affirm the judgment entered

in favor of defendants.

I. BACKGROUND

On February 25, 1983, police detectives in DuPage County went to the home of Tom and

Pat Nicarico in response to a report that the Nicaricos could not find their daughter, Jeanine. The

detectives saw that someone had kicked the front door open, and that person kicked hard enough

to leave an impression of his boot. Two days later, Jeanine was found dead from several severe

blows to the head.

An anonymous tip led police to question Alejandro Hernandez in March 1983. Police

later charged Hernandez, Steven Buckley and Rolando Cruz with the murder. Thomas Knight

led the prosecution. A jury found Cruz and Hernandez guilty of murder. Our supreme court

reversed the convictions and remanded for retrial. During a subsequent trial an officer admitted

that he had lied in the prior trial about the evidence against Cruz. The judge acquitted Cruz.

A number of journalists published stories about the events leading to the prosecution and

eventual acquittal of Cruz. Investigators began to look into the conduct of the police officers and

attorneys who constructed the case against Cruz. Some of the investigators, including Steven

-2- 1-06-0957

Kirby, spoke to a grand jury about their findings. Kirby told the grand jury that he interviewed

John Gorajczyk, who worked in the DuPage County crime lab in 1983. Gorajczyk compared

Buckley's boots to the imprint on the Nicaricos' front door. He concluded that Buckley's boots

did not make the imprint. Gorajczyk told the sheriff his findings. The next day the boots were

not in the crime lab. Gorajczyk never wrote a report of his findings. Other experts subsequently

compared Buckley's boots to the imprint and found a match.

During preparation for the trial of Cruz, Hernandez and Buckley, Knight learned of

Gorajczyk's initial examination and asked Gorajczyk why he had not written a report. Gorajczyk

told Knight he did not write a report because he had completed only a cursory examination,

without any notes, before the boots left the crime lab. According to the transcript of Kirby's

testimony to the grand jury, Kirby affirmed that "Knight's response was to tell Gorajczyk not to

discuss the matter with any one [sic] and not to report to anyone about his negative findings and

his failure to write a report."

The grand jury indicted four police officers and three prosecutors, including Knight, for

perjury and obstruction of justice in connection with their handling of the charges against Cruz,

Hernandez and Buckley. Some newspapers referred to the four officers and three attorneys

collectively as the DuPage 7.

Before the DuPage 7 trial began, Knight's attorney obtained in discovery transcripts of the

grand jury proceedings which led to the indictments against the DuPage 7. Knight's attorney

decided to send the complete transcripts, including the testimonies of all witnesses, to Ted

Gregory, a reporter for the Chicago Tribune.

-3- 1-06-0957

On January 12, 1999, the Tribune published an article entitled "Prosecution on trial in

DuPage," by Maurice Possley and Ken Armstrong. The article appeared in a series entitled "Trial

& Error: How Prosecutors Sacrifice Justice to Win." The reporters documented the incidents that

led up to the indictments of the officers and prosecutors. In the article they stated:

"At its core, the indictment of the DuPage 7 focuses on two key aspects of

the case: that on the eve of the first trial of Cruz *** [two detectives] concocted a

lie--that Cruz had told them of having a 'vision' of the crime that included details

only the killer would know. That lie, according to the indictment, was endorsed

and perpetuated by the prosecutors. In addition, prosecutors King and Kilander

are accused of concealing notes that showed there was an admitted killer named

Brian Dugan, a man who had already pleaded guilty to two other murders,

including the killing of a 7-year-old girl.

***

*** [Cruz] is expected to testify that what he told the officers and

prosecutors during the initial days of the investigation--words that ultimately

would become the basis for a case against him--was something he made up in

hopes of cashing in on a $10,000 reward.

In the weeks following the discovery of Jeanine's body, Hernandez ***

told detectives *** that three people committed the crime, including Buckley and

someone named 'Ricky.'

-4- 1-06-0957

While the detectives never found anybody named 'Ricky,' they picked up

Buckley, who turned over a pair of his boots for comparison with the print on the

front door. But Buckley denied any involvement in the crime.

Eager to capitalize on the reward, Hernandez and Cruz babbled incessantly

to the detectives and the grand jury investigating Jeanine's murder. ***

As the trial approached, lead prosecutor Thomas Knight summoned John

Gorajczyk, a shoe print examiner in the sheriff's police crime lab, to discuss his

examination of Buckley's boots, according to the grand jury transcripts.

Earlier, Gorajczyk had compared Buckley's boots to the print on the

Nicarico door and concluded they didn't match. He did not write any report about

his findings. Gorajczyk told the DuPage grand jury that Knight told him to keep

his mouth shut about his conclusion and not to tell anyone that there was no

written report.

Knight then sent the print and boots to the Illinois State Police crime lab,

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