Salzano v. North Jersey Media Group, Inc.

993 A.2d 778 (2010)

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Salzano v. North Jersey Media Group, Inc.

New Jersey Supreme Court
993 A.2d 778 (2010)

CS

Facts

In 2006, The Record, a newspaper owned by North Jersey Media Group, Inc. (North Jersey), published a report on a complaint filed by the bankruptcy trustee for NorVergence, Inc., against Thomas J. Salzano (plaintiff). The complaint, which had not yet come before a bankruptcy judge when the report was published, alleged Salzano misappropriated NorVergence’s funds for his personal benefit. The report stated that Salzano allegedly stole close to $500,000 from NorVergence and that Salzano and his father started a business the prior year that went belly-up. In addition to The Record, the report was published in several other print and online newspapers, accompanied by varying headlines and subheadings that used words such as stealing and stolen funds. Salzano sued North Jersey and the other newspaper publishers (publishers) (defendants) for defamation. The publishers filed a motion to dismiss, arguing that their reporting either was protected by the fair-report privilege or was not defamatory because it was accurate and not malicious. The trial court granted the motion to dismiss, but the intermediate appellate court reversed and remanded the case to the trial court. In so ruling, the intermediate appellate court held that the fair-report privilege did not apply because of the initial-pleadings exception, which precluded the fair-report privilege from applying to defamatory statements appearing in pleadings that had yet to come before a judge. The publishers appealed to the New Jersey Supreme Court on that issue.

Rule of Law

Issue

Holding and Reasoning (Long, J.)

Concurrence/Dissent (Hoens, J.)

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