Wednesday, January 1, 2014

Godbehere v. Phoenix Newspapers, Inc. case brief

Godbehere v. Phoenix Newspapers, Inc. case brief summary
783 P.2d 781 (1989)

CASE SYNOPSIS
Plaintiffs, sheriff and sheriff's employees, brought an action against defendant publishers for libel and false light invasion of privacy. The Court of Appeals (Arizona) dismissed the action. The sheriff and the employees appealed.

CASE FACTS
The publishers printed stories about the sheriff's and his employees' alleged incompetence and illegal activities. The publishers claimed that there was no separate cause of action for false light invasion of privacy because it merged with the tort of outrage or defamation.

DISCUSSION

  • The court vacated and remanded the appellate court's decision and held that the independent tort of false light existed in Arizona. 
  • While outrage provided redress for the same injuries as false light, the torts did not merge because they did not necessarily cover the same tortious activity. 
  • False light and defamation covered different interests. 
  • False light protected mental and emotional interests, notwithstanding whether the material was true, as opposed to defamation, which protected reputation and to which truth was a defense. 
  • However, the sheriff and the employees were required to show that the articles were published with knowledge of the false innuendo or with reckless disregard of the truth. 
  • False light only applied to private matters. 
  • Because law enforcement was a public matter and the articles related to how the duties were performed, the sheriff and the employees could not bring the false light claim.
CONCLUSION
The court vacated and remanded the decision for the publishers in the sheriff's and the employees' action for false light invasion of privacy.

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