Cockram v. Genesco, Inc.
United States Court of Appeals for the Eighth Circuit
680 F.3d 1046 (2012)
Jessica Cockram (plaintiff) worked at a Journeys retail store, owned by Genesco, Incorporated (defendant). One day, Keith Slater, an African American customer, brought merchandise back to the store to return it. Cockram entered a generic phone number into the register to speed up the return process. Previously, a former employee had entered a racial slur as one of the names linked to the phone number in the store’s database. Cockram unknowingly selected the entry with the racial slur for Slater’s return. Cockram printed a return receipt, which included the racial slur, and gave it to Slater. Slater returned to the store with several family members the next day to complain about the slur on the receipt. Genesco fired Cockram days later. Genesco released a statement regarding the incident. The statement could have been read to imply that Cockram intentionally communicated the racial slur to Slater. Multiple news stories quoted Genesco’s statement. Cockram was called racist and was threatened. She was so fearful that she moved out of her apartment and left her child to stay with her parents. Cockram eventually agreed to be interviewed but insisted her name be withheld. Cockram sued Genesco for defamation and false-light invasion of privacy. The district court dismissed the false-light claim and granted summary judgment in favor of Genesco on the defamation claim. Cockram appealed.
Rule of Law
Holding and Reasoning (Gruender, J.)
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