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Tavoulareas v. Piro

817 F.2d 762 (1987)

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Tavoulareas v. Piro

United States Court of Appeals for the District of Columbia Circuit

817 F.2d 762 (1987)

Facts

William Tavoulareas and his son Peter Tavoulareas (plaintiffs) sued the Washington Post (the Post) and certain employees (defendants) for injury to reputation after the Post published a lengthy article written by reporter Patrick Tyler about Peter’s appointment as a partner at Atlas, a shipping company. The article reported that William, who was president of the Mobil Corporation, personally urged Atlas executive George Comnas to hire Peter for a partner position. Atlas had a substantial shipping contract with Mobil, and the article suggested that the arrangement was set up for improper benefit. Comnas was the only source of the assertion that William personally urged Comnas to hire Peter. However, independent sources who the Tavoulareases conceded were reliable verified most of the other information Comnas provided to Tyler. Additionally, Comnas relayed the same information, including the claim that William urged him to hire Peter, to investigators for the House Subcommittee on Energy and Power as part of a formal investigation. Tyler spent a month researching and writing the story. The story underwent extensive review by Post senior editors and attorneys, who were satisfied with its accuracy and approved it for publication. After a federal jury trial finding in favor of the William and Peter, the district court awarded judgment notwithstanding the verdict to the Post because it did not find that William and Peter established by clear and convincing evidence that Tyler or the Post published the article with actual malice.

Rule of Law

Issue

Holding and Reasoning (Starr and Wright, JJ.)

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