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Chapin v. Knight-Ridder, Inc.

United States Court of Appeals for the Fourth Circuit

993 F.2d 1087 (1993)

Facts

Roger Chapin, through his charity, Help Hospitalized Veterans, Inc. (HHV) (plaintiffs), operated a program during the Persian Gulf War that sent “gift pacs” to soldiers in Saudi Arabia. At the peak of the program’s popularity, the Philadelphia Enquirer, a publication of Knight-Ridder (defendant), ran an article written by Frank Greve about the program. The article highlighted the high cost of purchasing a gift pac compared with the wholesale price of the items included and questioned what happened to the leftover money. The article suggested both favorable and unfavorable potential explanations and asked questions but did not draw any conclusions. The sale of gift pacs dropped substantially after the article was published. Chapin and HHV sued Knight-Ridder in Virginia federal court, arguing that the implications of Greve’s article, not the facts stated in it, were false and constituted libel. Knight-Ridder filed a motion to dismiss the libel claim because it was not actionable, which the district court granted. Chapin and HHV appealed the order granting the motion to dismiss.

Rule of Law

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Issue

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Holding and Reasoning (Hall, J.)

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