Barbara Robinson v. John Williams, No. 20-1636 (4th Cir. 2023)
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Plaintiff, a cardiothoracic surgeon, sued another cardiothoracic surgeon, Defendant, alleging that his remarks about her performance during an aborted surgery defamed her. On summary judgment, the district court determined that Defendant’s statements—that Plaintiff “misread” or “failed to recognize” the findings on the patient’s echocardiogram before beginning surgery—were not false, as Plaintiff admitted she did not read the echocardiogram at all before operating. The district court, therefore, concluded the statements could not be actionable under North Carolina law.
The Fourth Circuit vacated the summary judgment order. The court disagreed with the district court’s appraisal on summary judgment. The court explained that to say that Plaintiff “misread” the echocardiogram presupposes that she read it in the first place, which she did not. And the defamatory sting of Defendant’s statements—that Plaintiff either lacked skill in applying her medical judgment to interpret the echocardiogram or deviated from the standard of care by failing to evaluate the echocardiogram results before operating—presents a conclusion about which the parties, and the evidence, sharply disagree. For these reasons, the district court erred in finding no dispute of material fact as to the falsity of Defendant’s statements.
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