Jeffrey Lance Cruce v. Berkeley Cnt School Dist

Syllabus

Jeffrey Cruce, a former athletic director and head football coach at Berkeley High School, sued the Berkeley County School District (the District) for wrongful termination and defamation. The trial court granted the District a directed verdict on Cruce's wrongful termination claim and on Cruce's defamation claim related to the District's silence on why Cruce had been removed from his positions at Berkeley High. The trial court denied the District's motion for a directed verdict on Cruce's remaining defamation claim related to an email sent by a District employee about Cruce, ruling Cruce did not qualify as a public official or limited public figure, and as such, the District was not entitled to sovereign immunity the South Carolina Tort Claims Act (the Tort Claims Act). The jury found in Cruce's favor on his defamation claim and awarded him $200,000 in actual damages. In a published decision, the court of appeals reversed the trial court, finding Cruce was a public official, and thus, the Tort Claims Act barred Cruce's defamation claim. Cruce v. Berkeley Cnty. Sch. Dist., 435 S.C. 7, 21-22, 865 S.E.2d 391, 398-99 (Ct. App. 2021). We reverse the court of appeal's finding that Cruce was a public official, find Cruce was not a public official or limited public figure, and reinstate the jury's damages award.