Sutton v. Dept. of Rehab. & Corr.

Citations

• 2026 Ohio 1182

Syllabus

Civ.R. 56; motion for summary judgment; defamation; qualified privilege; negligence; public duty. Defendant was entitled to judgment as a matter of law on plaintiff's defamation claim, which alleged that defendant falsely accused plaintiff of being a co-conspirator with her husband in an extortion scheme, because defendant satisfied its burden by presenting evidence that the statements at issue were protected by qualified privilege. Defendant was likewise entitled to judgment as a matter of law on plaintiff's negligence claim arising from its investigation and publication of the allegations, as defendant was immune from liability under R.C. 2743.02(A)(3)(a), Ohio's public duty rule. Plaintiff failed to produce evidence demonstrating a genuine issue of material fact existed regarding qualified privilege or public duty. Judgment for defendant.