McKee v. LaurionAnnotate this Case
After David McKee, a physician, acted in a manner Dennis Laurion considered rule and insensitive, Laurion posted critical comments about McKee on various "rate-your-doctor" websites and also sent letters to several medically-affiliated institutions complaining about McKee's conduct. McKee commenced this action against Laurion, asserting claims for defamation per se and interference with business. The district court granted summary judgment for Laurion, concluding that the individual statements were either protected opinion, substantially true, or lacked defamatory meaning. The court of appeals reversed with respect to six of the alleged defamatory statements. The Supreme Court reversed, holding that none of the six statements was actionable either because (1) there was no genuine issue of material fact as to the falsity of the statements, or (2) the statements were not capable of conveying a defamatory meaning that would harm McKee's reputation and lower him in the estimation of the community.