Rocci v. Ecole Secondaire Macdonald-Cartier
New Jersey Supreme Court
755 A.2d 583 (2000)
- Written by Daniel Clark, JD
Facts
Ana Rocci (plaintiff) taught at a high school in New Jersey. Edward Tilli (defendant) taught at a high school in Ontario, Canada. Rocci and a group of her students joined Tilli and a group of his students for a trip to Spain. After the trip, Tilli wrote a letter to Rocci’s principal. In his letter, Tilli claimed that, on the trip, Rocci drank excessively, forced her students to stay out inappropriately late, and generally acted unprofessionally. Rocci’s principal did not discipline Rocci as a result of the letter, and Rocci suffered no substantial, tangible consequences because of the letter. Rocci sued Tilli for defamation. Rocci did not allege specific pecuniary damages but rather sought to recover under a theory of presumed damages. The trial court granted summary judgment in favor of Tilli, finding the letter not to be defamatory. The appellate court upheld the judgment but on the grounds that Rocci was required to show some demonstrable harm and that she had failed to do so. Rocci appealed to the New Jersey Supreme Court, which asked the parties to submit briefings on whether Tilli’s letter implicated the public interest.
Rule of Law
Issue
Holding and Reasoning (Verniero, J.)
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