Weidman v. Hildebrant

Citations

• 2022 Ohio 1708

Syllabus

The discovery rule applies to those libel actions where the publication of the defamatory statements was secretive, concealed, or otherwise inherently unknowable due to the nature of the publication. In such instances, a cause of action for defamation accrues when the plaintiff discovers, or by the exercise of reasonable diligence should have discovered, that he or she was injured by the wrongful conduct of the defendant. The discovery rule also applies to plaintiff's claims of intentional infliction of emotional distress and false light invasion of privacy, where such claims are inextricably premised on the same allegations that support the libel claim. The trial court erred by granting summary judgment to defendant on the basis that the plaintiff's claims were barred by the one-year statute of limitations set forth in R.C. 2305.11(A).