Russell Henry v. Media General Operations, Inc.

Syllabus

The plaintiff in the instant case, Captain Russell Henry, appealed from the April 11, 2018 entry of final judgment in Providence County Superior Court in favor of the defendants, Media General Operations, Inc., Chris Lanni, James Taricani, Officer Peter Leclerc, Ronald Jacob, and Captain Karen E. Guilbeault. Final judgment was entered in the case after the defendants' motions for summary judgment were granted. On appeal, Captain Henry contended that the trial justice erred in finding a police officer to be a \per se public official .\ He further posited that the trial justice erred in determining that defendants' broadcast of a purportedly false allegation was not the product of \actual malice\ as is constitutionally required if the plaintiff is classified as a public official in the defamation context. Captain Henry further averred that the \trial justice erred in granting summary judgment on [his] claims of negligent and intentional infliction of distress and violation of R.I. Gen. L. sec. 9-1-28.1 (false light).\ The Supreme Court held that Captain Henry was a public official. The Court further held that there was insufficient evidence on which a rational jury could conclude that any of the defendants had acted with actual malice. Finally, it was the Court's holding that Captain Henry's other claims failed because a party cannot breathe life into a doomed defamation claim by re-baptizing it as a different cause of action. Accordingly, the Supreme Court affirmed the judgment of the Superior Court.