State Farm Fire & Casualty Co. v. Radcliff
Indiana Court of Appeals
987 N.E.2d 121 (2013)
Facts
Joseph Radcliff (plaintiff) owned and operated a company that repaired hail-damaged homes. State Farm Fire & Casualty Company (State Farm) (defendant) publicly accused Radcliff of insurance fraud, leading to Radcliff’s highly publicized felony arrest. Radcliff’s business shut down, he suffered severe and ongoing reputational damage, and he incurred $7.5 million in lost earnings. The charges were subsequently dismissed, and State Farm sued Radcliff for fraud. Radcliff and his company counterclaimed for defamation. At trial, Radcliff testified that his business was forced to shut down because of State Farm’s wrongful actions. Experts testified that State Farm’s accusations had caused Radcliff to suffer $7.5 million in lost earnings and had damaged his reputation so badly that it was virtually unrecoverable. The jury found State Farm liable and awarded Radcliff and his company $14.5 million in damages. State Farm appealed. The Indiana Court of Appeals found that State Farm had committed defamation per se and analyzed the jury’s damages award.
Rule of Law
Issue
Holding and Reasoning (Vaidik, J)
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