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Maldonado v. Ford Motor Co.

719 N.W.2d 809 (2006)

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Maldonado v. Ford Motor Co.

Michigan Supreme Court

719 N.W.2d 809 (2006)

Facts

Justine Maldonado (plaintiff) sued Ford Motor Co. (defendant) claiming supervisor Daniel Bennett sexually harassed her. Before trial, the judge ruled Bennett’s prior conviction for indecent exposure was not admissible in Maldonado’s suit. On September 11, 2001, Maldonado’s attorneys issued a press release about the judge excluding the indecent exposure and the upcoming trial. A month later, Bennett had the conviction expunged. After a pretrial hearing, the judge warned Maldonado that if she continued to disseminate information about Bennett’s conviction, the judge would dismiss her case. Maldonado and her attorneys nonetheless met with the media, held “Justice for Justine” rallies, and distributed leaflets accusing the judge of being “in Ford’s pocket” and “trying to keep the truth out of the courtroom.” Bennett moved to dismiss the suit, and Maldonado’s counsel tried unsuccessfully to disqualify the judge. After Maldonado’s counsel appeared in a television interview accusing “Metro Detroit” judges of bias toward Ford five days before trial, the judge dismissed Maldonado’s case, finding the statements were likely to influence prospective jurors and prejudice the proceedings. Maldonado appealed. The appellate court found the applicable standard was whether the comments created “a substantial likelihood of material prejudice” but then ordered the matter remanded for an evidentiary hearing on whether actual prejudice occurred. Ford appealed.

Rule of Law

Issue

Holding and Reasoning (Corrigan, J.)

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