Horne v. WTVR, LLC

The Fourth Circuit affirmed the district court's grant of WTVR's motion for a directed verdict in a defamation action. Plaintiff filed suit against WTVR after it aired a news story about a county school system hiring a felon, in this case plaintiff, that lied about a prior criminal conviction on a job application. The court held that plaintiff was a public official, the allegedly defamatory statements related to her official conduct, and thus she was required to prove that WTVR acted with actual malice to succeed on her claim. Furthermore, the district court did not err in concluding that plaintiff presented insufficient evidence that WTVR made the defamatory statements with actual malice. Finally, the district court did not abuse its discretion in denying plaintiff's pre-trial motion to compel WTVR to disclose the identity of its confidential source where she did not provide a sufficiently compelling interest in the identity of the source to overcome competing First Amendment concerns. View "Horne v. WTVR, LLC" on Justia Law