McGuire v. Bowlin

932 N.W.2d 819
CourtSupreme Court of Minnesota
DecidedSeptember 4, 2019
DocketA18-0167
StatusPublished
Cited by17 cases

This text of 932 N.W.2d 819 (McGuire v. Bowlin) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McGuire v. Bowlin, 932 N.W.2d 819 (Mich. 2019).

Opinion

HUDSON, Justice.

Under New York Times Co. v. Sullivan , 376 U.S. 254, 84 S.Ct. 710, 11 L.Ed.2d 686 (1964), and its progeny, defamation plaintiffs who are "public officials" or "public figures" can recover in a defamation action only upon a showing of actual malice. See id. at 283-84, 84 S.Ct. 710 ;

*822Chafoulias v. Peterson , 668 N.W.2d 642, 648-49 (Minn. 2003). In this case, we must decide whether appellant Nathan McGuire, a public high school basketball head coach, falls into either of those categories. Having reviewed the undisputed facts regarding McGuire's duties as coach and regarding the lack of any controversy concerning his performance before the allegedly defamatory statements were made, we conclude that McGuire is neither a public official nor a public figure. However, because McGuire did not appeal the district court's conclusion that the statements of respondents Joy Szondy, Chelon Danielson, and Cheryl Hewitt fall under a qualified privilege, we nevertheless affirm summary judgment as to those three respondents. Because the district court granted summary judgment to respondent Julie Bowlin solely on the basis of McGuire's status as a public official, we reverse as to McGuire's defamation claim against her and remand for further proceedings on that claim.

FACTS

This case comes before us following the district court's grant of summary judgment against McGuire. Accordingly, we view the evidence in the light most favorable to him. See Expose v. Thad Wilderson & Assocs., P.A. , 889 N.W.2d 279, 284 (Minn. 2016).

From the fall of 2012 to the spring of 2014, McGuire was the head coach of the girls' basketball program for Woodbury High School. In that role, he oversaw five assistant coaches, made strategic decisions, scheduled games and practices, and had general oversight of the program.

While McGuire was coaching at Woodbury, respondents, all of whom were parents of players on the team, expressed concerns about McGuire's conduct, most notably alleging that he swore at practices, touched players in inappropriate ways,1 and flirted with players. In January 2014, these concerns ultimately culminated in Bowlin, Szondy, and Hewitt meeting with (and Danielson writing a letter to) school administrators to discuss McGuire's conduct. Two days after respondents met with the school administrators, McGuire was placed on administrative leave from his coaching duties. Two months later, in March 2014, the school district decided not to renew McGuire's coaching contract.

Around the same time, Bowlin and Danielson filed maltreatment-of-minor reports against McGuire with the Minnesota Department of Education. Following an investigation, the Department concluded that Bowlin's daughter had not been subjected to maltreatment. Although the record is silent as to Danielson's daughter, no evidence suggests that the Department reached a different conclusion as to her.

Even after McGuire was removed from his coaching position, Bowlin continued to make statements about him. In August 2014, she emailed another parent that, "Last I heard yesterday he was recently put in jail ... I will find out the truth and call the [Department of Education] today and find out." In December she sent that same parent's spouse a photo of a newspaper article titled "Woodbury man sentenced to jail in stolen funds case," accompanied by a text that said "I know we don't talk anymore but this was part of the Woodbury stuff with [McGuire] that was going on. This guy too got busted." It is undisputed that the subject of the article was not McGuire.

In December 2015, McGuire served and filed a complaint alleging respondents had engaged in defamation and a civil conspiracy, and that Bowlin and Danielson had *823filed false maltreatment-of-minor reports.2 Following discovery, Szondy, Danielson, and Hewitt moved for summary judgment. They alternatively argued that because (1) McGuire was a public official, (2) McGuire was a public figure, or (3) their statements were made under a qualified privilege, McGuire was required to prove malice and there was no such proof here. The district court granted their motions, dismissing all claims against Szondy and Hewitt, as well as the defamation claim against Danielson. Four months later, Bowlin and Danielson filed new motions for summary judgment, Bowlin as to all claims against her and Danielson as to the remaining false-reporting and civil-conspiracy claims against her. The district court granted the motions reasoning that McGuire was a public official and that there was no evidence that Bowlin or Danielson "knowingly or recklessly" made a false report. The district court did not reach the issue of whether McGuire was a public figure.

In the court of appeals, McGuire appealed the issues of whether he was a public official, whether there was any genuine issue of material fact that respondents acted with actual malice, and whether there was any genuine issue of material fact that Bowlin3 knowingly or recklessly filed a false maltreatment-of-minor report. In an unpublished opinion, the court of appeals affirmed the district court's decisions. McGuire v. Bowlin , No. A18-0167, 2018 WL 6273533 (Minn. App. Dec. 3, 2018). The court held that McGuire was a public official, that nothing in the record showed that respondents acted with actual malice, and that there was no evidence that Bowlin knowingly or recklessly filed a false maltreatment report. Id. at *4-6.

McGuire petitioned for further review solely on the issue of whether he was a public official for the purpose of his defamation claims. We granted his petition.

ANALYSIS

I.

McGuire appeals the court of appeals' conclusion that he is a public official. Whether McGuire is a public official is a question of law that we review de novo. Britton v. Koep , 470 N.W.2d 518, 520 (Minn. 1991).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
932 N.W.2d 819, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcguire-v-bowlin-minn-2019.