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Chapadeau v. Utica Observer-Dispatch, Inc.
New York Court of Appeals
341 N.E.2d 569 (1975)
Facts
Joseph Chapadeau (plaintiff), a public school teacher, was arrested for possession of a hypodermic needle and possession of heroin. The Utica Observer-Dispatch (the Observer-Dispatch) (defendant) published an article the following day that included information about Chapadeau’s arrest and the drug-related arrests of two other individuals. The article reported that the trio were arrested at a party in a park where drugs and alcohol were found. These statements were true regarding the other two individuals, but Chapadeau was not at the park, at the party, or in any way connected to the other two. To prepare the article, the reporter interviewed the police captain and reviewed police documents. Neither source placed Chapadeau at the party or linked him to the other two arrestees. Two Observer-Dispatch employees other than the writer checked the article before it was published. The Observer-Dispatch acknowledged the statements were false but moved for summary judgment on the ground that the article was fair and true as a whole. The trial court denied the motion for summary judgment. The appellate division reversed. Chapadeau appealed, arguing that the Observer-Dispatch’s failure to catch the error tying him to the party and the arrest of the other two individuals precluded summary judgment.
Rule of Law
Issue
Holding and Reasoning (Wachtler, J.)
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