Hearst Corp. v. Hughes
Maryland Court of Appeals
466 A.2d 486 (1983)
- Written by Sara Adams, JD
Facts
Wayne Hughes (defendant) was employed by a car dealership, Security AMC/Jeep, Inc. (Security), as an operating manager. Security had bought out another dealership, Forty West AMC/Jeep, Inc. (Forty West). A customer had purchased a defective vehicle from Forty West and had brought the car in for repairs several times, though the defects were never corrected. After the buyout of Forty West, the customer brought the car to Security. Although the car had not been sold by Security and the warranty was expired, Hughes received special permission to perform warranty services on the car. The car was eventually fixed and deemed safe to drive. Frustrated with her experiences, the customer made complaints to several groups, including local television station WBAL-TV, which was owned by the Hearst Corporation (plaintiff). WBAL-TV broadcast a video of the customer reading a letter of complaint addressed directly to Hughes, which blamed him for the car issues and implied that she had purchased the car from him and Security. Hughes sued for defamation. The trial court found that the letter was defamatory, and that Hearst negligently broadcast the video. Although the trial court found no evidence that Hughes suffered actual losses or impairment to his reputation, Hughes was awarded $2,500 in compensatory damages for emotional distress. Hearst appealed the damages award and petitioned for a writ of certiorari, which was granted. Hearst argued that damages for emotional distress may not be awarded without evidence of injury to Hughes’s reputation.
Rule of Law
Issue
Holding and Reasoning (Rodowsky, J.)
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