McClure v. Ohio Dept. of Rehab. & Corr.

Citations

• 2020 Ohio 1035

Syllabus

Court of Claims did not err when it granted summary judgment in favor the Ohio Department of Rehabilitation & Correction (\DRC\) as to inmate's defamation claim. Though the oral defamatory statements allegedly made by a DRC employee directly accused appellant of being a troublemaker, know-it-all, and poor dog handler, because those statements did not import an indictable criminal offense involving moral turpitude or infamous punishment, impute some loathsome or contagious disease which would exclude appellant from society, or tend to injure appellant in his trade or occupation, appellant's failure to plead and produce evidence of special damages was fatal to his slander claim. Similarly, because the written statement made by a DRC employee disparaged appellant's reputation as a model inmate and accused him of being a poor dog handler only by inference, appellant's failure to either plead or produce evidence of special damages entitled DRC to judgment, as a matter of law. Judgment affirmed.