Todd Andreacchio v. Joseph Hamilton

Syllabus

This appeal involves a claim of intentional or, alternatively, negligent infliction of emotional distress. Christian Andreacchio, son of Todd and Rae Andreacchio (\Plaintiffs\), died in Meridian, Mississippi. The Meridian Police Department ruled Christian Andreacchio's death a suicide. Plaintiffs contend that, contrary to the official conclusion, their son was murdered. Joseph (aka Joel) Hamilton (\Defendant\) created a Facebook page to express his own opinions on the matter. Defendant has argued publicly in favor of the Meridian Police Department's conclusion. Plaintiffs sued Defendant and John Does 1-100 in the Circuit Court for Dickson County (\the Trial Court\) for distributing Christian Andreacchio's autopsy photographs online. The photographs were public records released by the Mississippi Attorney General's Office. Defendant filed a motion for summary judgment, which the Trial Court granted. Plaintiffs appeal. Plaintiffs argue that Defendant exceeded the bounds of constitutionally protected speech by distributing their son's autopsy photographs online. The undisputed material facts show that the information Defendant is alleged to have shared is truthful information, public records, concerning a matter of public significance. We hold, as a matter of law, that Plaintiffs cannot prevail on their claims. We affirm.