Longbehn v. Schoenrock

Patrick Longbehn (plaintiff), a 34-year-old trainee police officer, became widely known in his community by the nickname “Pat the Pedophile” after he began dating an 18-year-old. The police department fired Longbehn at the end of his probationary period. According to the police chief, Longbehn was fired because he had lost credibility in the community due to a perception that he was overzealous and overbearing. The police chief stated that, although the offensive nickname reflected Longbehn’s lack of credibility, it was not the reason he was fired. Instead of looking for another job as a police officer, Longbehn took a job with the department of corrections but was fired during his training period for assaulting his girlfriend, who was also one of his coworkers. Longbehn filed a defamation lawsuit against Robin Schoenrock (defendant), an individual who had on one occasion called Longbehn “Pat the Pedophile” in public. A jury found Schoenrock liable for defamation per se and awarded Longbehn general, special, and punitive damages. The special damages award included $90,000 for past and future lost wages, and the general damages award included $233,000 for past and future harm to Longbehn’s reputation, mental distress, humiliation, and embarrassment, as well as for future healthcare expenses. Schoenrock moved for a judgment as a matter of law. The trial court granted the motion, holding that the offensive nickname was not per se defamatory and that Longbehn had failed to prove special damages. Longbehn appealed. The Minnesota Court of Appeals found that Schoenrock had per se defamed Longbehn and then turned to an analysis of the jury’s damages award.