Idlibi v. Hartford Courant Co.

Citations

• 216 Conn. App. 851

Syllabus

The self-represented plaintiff, a pediatric dentist, sought to recover damages for, inter alia, defamation and intentional misrepresentation in connec- tion with two articles published by the defendant. The articles concerned the plaintiff's disciplinary proceedings before the Connecticut State Den- tal Commission (commission) that stemmed from a complaint about his treatment of a three year old child. A reporter employed by the defendant contacted the plaintiff after he learned of a similar complaint against another dentist at the plaintiff's dental practice. The reporter left the plaintiff a voicemail, in which he asked for an interview. The parties disputed whether the reporter informed the plaintiff in that voicemail or in subsequent conversations that he would be the subject of the published articles. The defendant filed a motion for summary judgment on all counts of the plaintiff's complaint, arguing, inter alia, that it was protected from liability for defamation under the fair report privilege and substantial truth doctrine and that the plaintiff's intentional misrepresentation claim was legally insufficient. In his objection to the motion for summary judgment, the plaintiff pointed to specific state- ments in the articles to which he objected, including the headline of the first article, and argued that the recorded voicemail from the reporter provided sufficient evidence to support his claim of misrepresentation. The court granted the defendant's motion for summary judgment, con- cluding that the alleged defamatory statements were protected under either the fair report privilege, which protects the publication of a report of an official action or proceeding that deals with a matter of public concern if the report is accurate and complete or a fair abridgment of the proceeding, or the substantial truth doctrine. Moreover, on the basis of an email exchange between the reporter and a senior editor employed by the defendant, which indicated that the original d