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Crump v. Beckley Newspapers, Inc.

320 S.E.2d 70 (W. Va. 1984)

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Crump v. Beckley Newspapers, Inc.

Supreme Court of West Virginia

320 S.E.2d 70 (W. Va. 1984)

Facts

In 1977, Sue Crump (plaintiff) allowed a photograph of her to be taken by Beckley Newspapers, Inc. (Beckley Newspapers) (defendant) for use in an article concerning women who were coal miners. In 1979, Beckley Newspapers published another article that addressed many of the problems facing women who were coal miners, including specific instances of harassment and discrimination. The photograph of Crump from the 1977 article was presented alongside the 1979 article without her knowledge or consent. Crump began receiving unfavorable attention in connection with the article and eventually brought an action for defamation and false-light invasion of privacy against Beckley Newspapers. The trial court granted Beckley Newspapers’ motion for summary judgment, finding that Beckley Newspapers had a qualified privilege to publish the photograph because of the newsworthiness of the article and the relevance of the photograph. Crump appealed the decision.

Rule of Law

Issue

Holding and Reasoning (McGraw, C.J.)

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