Henry v. Media General Operations, Inc.
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The Supreme Court affirmed the judgment of the superior court in favor of Defendants in this case involving an allegedly defamatory report that was broadcast on the evening news, holding that the hearing justice did not err in granting Defendants' motions for summary judgment on all counts in the complaint.
Captain Russell Henry of the Cranston Police Department filed this action against Media General Operations, Inc. and several individuals alleging that NBC 10 WJAR, which was owned and operated by Media General, published reports that were false and defamatory as to Captain Henry. The hearing justice concluded that Captain Henry was a public official and that he could not prove, by clear and convincing evidence, that Defendants acted with actual malice in disseminating the allegedly defamatory information at issue. The Supreme Court affirmed, holding (1) Captain Henry was a public official at the time of the broadcast; and (2) there was insufficient evidence to allow a reasonable juror to conclude that broadcast was made with actual malice.
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