Collins v. Detroit Free Press, Inc.

Congressperson Barbara Collins (plaintiff) was seeking reelection in Detroit. Collins was interviewed by Ann Hazard-Hargrove, an employee of State News Service (defendants). The interview tape-recording and transcript were provided to Detroit Free Press, Inc. (DFP) (defendant). DFP published an article reporting that Collins said, “All white people, I don’t believe are intolerant. That’s why I say I love the individuals, but I hate the race.” Collins was also quoted as saying, “I’ve got a lot of friends who are white. At one time, all my friends were white, so it’s like I don’t like the race, I like the individuals”; “God is going to have to burn [racism] out of white people”; and Martin Luther King Jr. was successful only “because he said if blood had to flow, let it be my black blood, and not the blood of my white brother, and white people like to hear that kind of stuff.” Collins used the words “love,” “like,” “hate,” and “don’t like” throughout the interview. In response to the story, Collins issued a press release explaining that she had been summarizing her thoughts on racism by stating that she hated the sins committed by the white race against people of color. After Collins lost the primary election for her congressional seat, DFP published a retraction, admitting that Collins had not been quoted correctly. DFP acknowledged that what Collins had actually said was, “That’s why I say, I love the individuals, but I don’t like the race.” Collins sued DFP, Hazard-Hargrove, and State News Service (collectively, the press) for defamation. The trial court denied the press’s motion for summary disposition of the defamation claim, finding that “hate” and “not like” had substantially different meanings and the word “hate” could have a major effect on readers in a city like Detroit. The press appealed.