Cantrell v. Forrest City Publishing Comany

Brief Fact Summary.

Defendant’s newspaper published a story about a family that emphasized the family’s abject poverty. The family sued alleging that defendant invaded their privacy by placing them in an objectionable false light in the public eye.

Synopsis of Rule of Law.

A newspaper may be liable for publishing statements that it knows falsely or recklessly disregards the truth.

Facts.

Melvin Cantrell died after an Ohio bridge collapsed. The Plain Dealer newspaper wrote a story on the funeral of Melvin Cantrell and how his death impacted his family. Five months later, the writer and photographer (co-defendants) from the newspaper visited the Cantrell home again to write and photograph a follow-up feature. The article was published and contained numerous falsehoods, including an assertion that Margaret Cantrell refused to talk about the family. In reality, Margaret Cantrell was not home during the visit. The article also emphasized the Cantrells’ abject poverty. Margaret Cantrell and four of her minor children (plaintiffs) brought suit against Forest City Publishing Company (co-defendant), the publisher of The Plain Dealer, as well as the writer and photographer. The Cantrell family alleged the article made them the objects of pity and ridicule.

Issue.

Whether the appellate court erred in setting aside the jury’s verdict?

Held.

Yes. The judgment of the appellate court is reversed and the case is remanded so that court can enter a judgment affirming the judgment of the district court.

Discussion.

The district court judge struck the punitive damages claim because Mrs. Cantrell had not proven that the invasion of privacy was done maliciously. When the district court judge dismissed the punitive damages claim, he did so in reference to the common-law standard of malice—not the “actual malice” standard from New York Times v. Sullivan. However, the appellate court erroneously assumed that the New York Times “actual malice” standard was controlling here. Thus, the appellate court erred in setting aside the jury’s verdict.