MacElree v. Philadelphia Newspapers, Inc.

In 1991, the Philadelphia Inquirer, a newspaper owned by Philadelphia Newspapers, Inc. (defendant) published an article by B.J. Phillips (defendant) that discussed a fight that occurred on a college campus in Chester County, Pennsylvania. The article included a statement, purportedly made by the college’s lawyer, that accused Chester County’s district attorney, James MacElree (plaintiff) of electioneering and likened MacElree to David Duke, a former Ku Klux Klan leader and politician known for expressing racist views (the statement). Although MacElree did not believe the college’s lawyer made the statement, MacElree sued Phillips and Philadelphia Newspapers, claiming the statement was defamatory. The trial court sustained preliminary objections raised in a demurrer filed by Phillips and Philadelphia Newspapers. The intermediate appellate court affirmed, agreeing with the trial court that the statement did not constitute actionable defamation and holding that MacElree’s suit had to be dismissed unless a reasonable person would read the statement, taken in context, as defamatory. The intermediate appellate court said that the reference to Duke was simply a metaphor and that the statement merely accused MacElree of being a racist. The intermediate appellate court also noted that the statement comprised only a small portion of Phillips’s article and said that, overall, the article presented MacElree in a more favorable light than it did the college’s officials. MacElree appealed the decision of the intermediate appellate court to the Pennsylvania Supreme Court.