The New Mexico Supreme Court overturned an appellate court's decision and clarified grounds for defamation lawsuits in the state when the high court ruled against a retired Episcopal priest who sued parishioners who accused him of pedophilia.
“Injury to reputation is the very essence of the tort of defamation,” Justice Patricio Serna said in the court opinion. “Evidence of humiliation and mental anguish, without evidence of actual injury to reputation, is insufficient to establish a cause of action for defamation.”
According to court documents, Rev. Walter F. Smith III, a priest at St. Francis Episcopal Church in Rio Rancho, filed a defamation suit in 2006 against four individuals – Will and Denise Durden and William and Marion DeVries – after they published and distributed packets alleging sexual misconduct between the priest and children at the church.
The packets were originally created for the regional leaders of the Diocese of the Rio Grande by parishioners who wanted Smith removed from his position. Smith has since retired. These packets were later distributed to an unknown number of churchgoers after Smith announced the allegations to the congregation. Included with the letter, the packets contained information on church financial short-comings and documents alleging a lack of leadership by the priest, according to court documents.
In August 2010, the New Mexico Court of Appeals reversed the district court‘s ruling, which was in favor of the defendants. The defendants' attorneys argued that Smith failed to provide evidence that the distribution of the letter caused actual injury to his reputation. The court held – in a two to one decision – that mental anguish and humiliation were evidence enough to support an actual injury claim, at least to establish liability for the damages.
Essentially the appellate court changed the state's definition of libel and jury instructions, said Hal Simmons, legal counsel for the New Mexico Press Association. The Press Association along with the New Mexico Broadcasters Association filed a friend-of-the-court brief to the state Supreme Court expressing concern over the Court of Appeals' decision, stating the ruling "undercut 25 years of defamation jurisprudence in New Mexico and in doing so has weakened the First Amendment protection in the state."
On Monday, the New Mexico Supreme Court unanimously reversed this decision.
Clarifying the state's defamation law, the court concluded that one must lay out all elements of a defamation case – including evidence that communications damaged his or her reputation – before liability for defamation can be determined and damages awarded. The court found that the district court ruled correctly because Smith was never suspended or let go from his position at the church and did not demonstrate actual injury, the high court's opinion said.
"It’s a real advance for the news media to have this definition of the libel set out so clearly in this New Mexico Supreme Court case," Simmons said. "The bottom line is it’s now not as easy for plaintiffs to recover in libel cases because of that threshold definition of libel."
Related Reporters Committee resources:
· Dig.J.Leg.Gd.: Defamatory statements about conduct