Martin v. Hearst Corp., No. 13-3315 (2d Cir. 2015)Annotate this Case
Plaintiff filed suit against media outlets after they accurately reported her arrest and charge for various drug-related offenses. Plaintiff claimed that the published articles, while factually true at the time of publication, became false and defamatory when her charges were nolled and the records of her arrest and prosecution erased under Connecticut's Criminal Records Erasure Statute, Conn. Gen. Stat. 54-142a. The court affirmed the district court's grant of summary judgment for defendants, concluding that the Erasure Statute does not render tortious historically accurate news accounts of an arrest. While reporting plaintiff's arrest without an update may not be as complete a story as plaintiff would like, it does not imply anything false about her.