Sheckler v. Virginia Broadcasting Corp.

63 Va. Cir. 368, 2003 Va. Cir. LEXIS 354
CourtCharlottesville County Circuit Court
DecidedNovember 7, 2003
DocketCase No. (Law) 02-60
StatusPublished

This text of 63 Va. Cir. 368 (Sheckler v. Virginia Broadcasting Corp.) is published on Counsel Stack Legal Research, covering Charlottesville County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sheckler v. Virginia Broadcasting Corp., 63 Va. Cir. 368, 2003 Va. Cir. LEXIS 354 (Va. Super. Ct. 2003).

Opinion

By Judge Edward L. Hogshire

This is to address defendant Virginia Broadcasting Corporation’s (“Defendant”) Motion To Set Aside the Verdict and for aNew Trial (Either in Toto or on the Issue of Damages Only), or in the Alternative, for Remittitur, challenging the award of damages in the above-named defamation action.

Before addressing the merits of the Motion before the Court, it should be noted that certain core facts in the case were not in dispute. For example, the Defendant’s broadcasts in question, having occurred on April 6th and 7th and again on October 29th and 30th of 2001, contained inaccurate information regarding Plaintiffs arrest for conspiracy to distribute cocaine, namely that law enforcement officers found fifty grams of crack cocaine and five hundred grams of powder cocaine at Plaintiffs residence and business. One of the broadcasts also displayed a photo of an unidentified man being arrested near the doorway of a home or business. These stories appeared over the air and on cable television and were also uploaded to the station’s website. After a criminal jury trial in the U.S. District Court in Charlottesville, the Plaintiff was acquitted of the criminal charge on October 31, 2001.

Over the three days of this civil trial, the jury heard from the Plaintiff, members of his family, his treating psychiatrist, and many friends. They also heard testimony from an expert witness who, over the objection of the [369]*369Defendant, was permitted to testify regarding applicable journalistic standards of care. The Defendant’s reporters involved in the defamatory broadcasts testified both in person and through a video deposition, as did the Defendant’s news director and manager. There was testimony from Plaintiffs former attorneys regarding efforts to secure a correction or retraction. Each side called an expert witness to testify regarding Plaintiffs mental health and emotional condition. The Plaintiffs expert, Dr. Shemo, and the Defendant’s expert, Dr. Cohen, agreed that the Plaintiff was suffering from depression, but did not agree on the cause and on whether he was also suffering from post-traumatic stress disorder.

The jury also heard testimony from the DEA agent who was in charge of the criminal investigation that led to Plaintiffs arrest and from the Assistant U.S. Attorney who prosecuted the case. It was this Assistant U.S. Attorney who was named by one of Defendant’s reporters as the source of the incorrect information in the broadcasts. His secretary also testified about having conversations with various reporters. There was no dispute that the Plaintiff was in fact arrested at a local filling station, not at his home or business, and charged with conspiracy to distribute cocaine. It was also not disputed that the U.S. Attorney’s office filed a lien against the Plaintiffs real estate. The jury here also heard much about the criminal prosecution, including the evidence that the Plaintiff had loaned a substantial sum of money without collateral or documentation to a man who later was shown to have been distributing large quantities of cocaine. The Defendant presented testimony of reporters from two local newspapers that also covered the Plaintiffs criminal prosecution and whose stories were also less than factually accurate and potentially defamatory.

At the conclusion of the trial, the jury here returned with a finding of liability against the Defendant television station and awarded Plaintiff $10,000,000.00, all as compensatory damages, the full amount sought. It is from this verdict that the Defendant seeks relief.

As grounds for the Motion, Defendant has listed a number of allegedly erroneous rulings by this Court, including the failure to give proffered defense instructions N and O, the admission of expert testimony on journalistic standards of care, and the admission of testimony by a former counsel for Jesse Sheckler, the plaintiff, concerning a requested retraction. These issues have been argued extensively by the parties and carefully considered by the Court on previous occasions, both before and during trial. Suffice it to say that the Defendant has not cited a sufficient basis for the Court to reconsider its previous rulings on these issues.

[370]*370The remaining grounds for the Motion, however, raise new issues and present serious concerns regarding the legal viability of the jury’s award. These include whether the award is excessive, whether the award has the First Amendment implications, and whether the Plaintiff’s evidence was sufficient to prove that the damages alleged were proximately caused by the defamatory parts of the subject broadcasts. After carefully reviewing the trial transcript, the Court has concluded that liability was clearly established by the evidence in the case and that the jury had ample evidence upon which to find the Plaintiff suffered severe emotional distress, as well as the elements of damages set forth in the damages instruction given to the jury without objection. This instruction allowed the jury to assess the “probable and natural effect upon Jesse Sheckler’s personal feelings and upon his standing in the community and in his business ... any insult to him including any pain, embarrassment, humiliation, and mental suffering; and any injury to his reputation.” (Instruction No. 13, from the Virginia Model Jury Instruction No. 37.100.)

But that does not end the inquiry. Plaintiffs counsel concedes that there was no evidence of lost income, but cites the “impact of the defamation on his business.” (Pl.’s Opp’nDef’s Post-Trial Mot. at 10 (hereinafter “PI. Mem.”).) There was credible evidence of loss of customers even though the Plaintiffs income levels did not decrease, but actually increased over the short term following the challenged broadcasts. The issue is whether these losses were caused by the defamatory publication or simply from the total impact of the negative publicity and attendant loss of reputation from Plaintiffs Federal prosecution and trial. In addition, the Plaintiff has also acknowledged that there were no medical expenses proven or offered into evidence; consequently, these expenses could not have been a part of the jury’s consideration.

Thus refined, the primary issue remaining is whether the verdict, based solely on intangible factors as set forth in the above-quoted instruction, is so excessive as to require the Court to set it aside and order a new trial, or, in the alternative, a new trial limited solely to damages or, finally, to require the Plaintiff to remit a portion of the award or submit to a new trial limited to damages alone.

Under § 8.01-383 and § 8.01-383.1 of the Code of Virginia, where damages awarded are too small or too excessive, courts have the authority to order a new trial, on all issues or solely on the issue of damages, or remittitur.

§ 8.01-383. Power to grant new trial; how often. - In any civil case or proceeding, the court before which a trial by jury is had, may grant a new trial, unless it be otherwise specially provided. A new [371]*371trial may be granted as well where the damages awarded are too small or where they are excessive. Not more than two new trials shall be granted to the same party in the same cause on the ground that the verdict is contrary to the evidence, either by the trial court or the appellate court, or both.
§ 8.01-383.1. Appeal when verdict reduced and accepted under protest; new trial for inadequate damages. — A.

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Bluebook (online)
63 Va. Cir. 368, 2003 Va. Cir. LEXIS 354, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sheckler-v-virginia-broadcasting-corp-vacccharlottesv-2003.