Todd M. Stevens Vs. Iowa Newspapers, Inc., Susan Harman And Erik Brooks

CourtSupreme Court of Iowa
DecidedMarch 9, 2007
Docket78 / 04-0987
StatusPublished

This text of Todd M. Stevens Vs. Iowa Newspapers, Inc., Susan Harman And Erik Brooks (Todd M. Stevens Vs. Iowa Newspapers, Inc., Susan Harman And Erik Brooks) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Todd M. Stevens Vs. Iowa Newspapers, Inc., Susan Harman And Erik Brooks, (iowa 2007).

Opinion

IN THE SUPREME COURT OF IOWA No. 78 / 04-0987

Filed March 9, 2007

TODD M. STEVENS,

Appellant,

vs.

IOWA NEWSPAPERS, INC., SUSAN HARMAN and ERIK BROOKS,

Appellees.

On review from the Iowa Court of Appeals.

Appeal from the Iowa District Court for Story County, William J.

Pattinson, Judge.

Plaintiff in libel case appeals from summary judgment for defendants.

COURT OF APPEALS DECISION AFFIRMED; DISTRICT COURT

JUDGMENT REVERSED; CASE REMANDED.

Theodore F. Sporer of Sporer & Ilic, P.C., Des Moines, for appellant.

Michael C. Cox of Koley Jessen, P.C., Omaha, Nebraska, for appellees. 2

LARSON, Justice.

Todd Stevens brought a libel suit against Iowa Newspapers, Inc., as

owner, and Susan Harman and Erik Brooks, reporter and editor,

respectively, of the Ames Tribune. The district court granted the defendants’

motion for summary judgment, and the plaintiff appealed. The court of

appeals affirmed in part and reversed in part. We granted further review

and now affirm the decision of the court of appeals, reverse the judgment of

the district court, and remand.

I. Facts and Prior Proceedings.

The facts, as produced in the summary judgment record, are

undisputed. In November 1998 Todd Stevens orally agreed with Iowa

Newspapers to provide weekly sports columns to the Tribune to be paid on a

per-column basis. He was not an employee of the newspaper, but was

considered a freelance journalist subject to the Tribune’s editorial policies

and decisions.

In June 2002 Susan Harman, the sports section editor, wrote and

published a column about the resignation of Iowa State University’s

associate athletic director, Elaine Hieber. Stevens disagreed with the tone

of Harman’s article, believing it was too complimentary toward the resigning employee, and drafted his own column expressing his viewpoint. After

reviewing Stevens’ proffered article, Harman and David Kraemer, the

Tribune’s managing editor, decided the column would not be published

without further discussion with Stevens because of the column’s negative

comments and implications concerning the quality of the newspaper’s

investigation and reporting of the incident.

Stevens redrafted his column, toning down his attack on the

newspaper’s investigation, but Harman and Kraemer still refused to publish 3

it. In the meantime, Stevens read his column on the air on a local sports

radio talk program.

Stevens advised Kraemer that he would no longer write for the

Tribune and asked to write a “farewell” column. Kraemer consented, and

the column was published in the Tribune on June 10, 2002, under the

heading “Point Counterpoint—Columnist Opts Out of the Tribune.” Directly

adjacent to Stevens’ column was a response authored by Harman. Three

comments in Harman’s response became the basis of Stevens’ libel action:

(1) That Stevens “in fact rarely attended events upon which he wrote

columns”; (2) that Stevens’ original column on Hieber’s resignation

“contained numerous factual errors and unsubstantiated claims”; and

(3) that Stevens’ redraft of his Hieber resignation column “continued to

include fatal factual errors and near libelous characterizations.”

Stevens sued on a theory of express libel, and the district court found

that Stevens also had possibly pled a theory of defamation by implication.

Even though the district court was not convinced that defamation by

implication existed in Iowa law, it considered that possibility in its ruling.

We begin the discussion of the merits of this appeal by first

determining the plaintiff’s status⎯an important consideration in defamation cases. For defamation purposes, a person becomes a public figure in two

ways.

In some instances an individual may achieve such pervasive fame or notoriety that he becomes a public figure for all purposes and in all contexts. More commonly, an individual voluntarily injects himself or is drawn into a particular public controversy and thereby becomes a public figure for a limited range of issues. In either case such persons assume special prominence in the resolution of public questions. 4

Gertz v. Robert Welch, Inc., 418 U.S. 323, 351, 94 S. Ct. 2997, 3013, 41

L. Ed. 2d 789, 812 (1974). Stevens apparently admits, for libel purposes,

that he is a public figure.

Stevens, as a public figure, had the burden to show that a reasonable

jury could find by clear and convincing evidence that (1) the challenged

statements in Harman’s column were false and (2) Harman made the

statements with “actual malice.” See New York Times Co. v. Sullivan, 376

U.S. 254, 279-80, 84 S. Ct. 710, 726, 11 L. Ed. 2d 686, 706 (1964); Carr v.

Bankers Trust Co., 546 N.W.2d 901, 904 (Iowa 1996). The district court

ruled that Stevens failed to meet this test and granted the defendants’

motion for summary judgment.

The court of appeals affirmed the district court’s findings on

statements 2 and 3 (quoted above), reversed on statement 1 (that Stevens

rarely attended the events upon which he wrote columns), and remanded

for trial. The court of appeals, noting a split of authorities on the issue,

concluded Iowa would recognize a claim for defamation by implication.

II. Review of Summary Judgment.

The standard of review for summary judgment cases is well settled.

We review summary judgment motions for correction of errors at law. Carr, 546 N.W.2d at 903. Summary judgment is appropriate only when the entire

record demonstrates that no genuine issue of material fact exists and the

moving party is entitled to judgment as a matter of law. Id. We review the

evidence in the light most favorable to the nonmoving party. Mason v.

Vision Iowa Bd., 700 N.W.2d 349, 353 (Iowa 2005).

A party resisting a motion for summary judgment cannot rely on the

mere assertions in his pleadings but must come forward with evidence to

demonstrate that a genuine issue of fact is presented. The record on

summary judgment includes the pleadings, depositions, affidavits, and 5

exhibits presented. Carr, 546 N.W.2d at 903. Unique rules apply in

defamation cases because First Amendment rights are implicated. Id. at

904 (holding that the court “must examine the evidence to determine if a

rational fact finder could conclude that malice had been established by

clear-and-convincing evidence”).

III. Defamation by Implication.

The statements at issue, i.e., that Stevens rarely attended the events

he covered; that his original column contained numerous factual errors and

unsubstantiated claims; and that Stevens’ redraft continued to include

factual errors and “near” libelous characterizations, were all basically true.

It is only when the statements are given the spin that Stevens attributes to

them that they may be considered libelous. This raises the initial question

of whether we recognize defamation by implication. 1

Defamation by implication arises, not from what is stated, but from

what is implied when a defendant

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