William Armstrong v. Karen Thompson, et al.

Summary

The District of Columbia Court of Appeals reviewed summary judgment against William Armstrong on defamation, false light, publication of private facts, intentional infliction of emotional distress, and intentional interference with contractual relations claims arising from anonymous letters sent to the USDA. The court affirmed summary judgment on the defamation and privacy-related claims, concluding that the challenged statements were substantially true or nonactionable opinions. It reversed as to intentional interference with contractual relations because genuine issues of material fact could support a jury finding for Armstrong.

Holdings

1. Summary judgment for defendants was proper because the challenged factual statements were substantially true and the remaining challenged statements were nonactionable opinions lacking an objectively verifiable factual foundation.
2. Summary judgment was proper because the letters were not publicized to the public at large or to so many persons that they were substantially certain to become public knowledge, and they were not about false statements as a matter of law.
3. Summary judgment was proper because the letters did not satisfy the publicity requirement for publication of private facts.
4. Summary judgment was proper because no reasonable juror could find that Armstrong suffered severe emotional distress or that Thompson's conduct was sufficiently extreme and outrageous.
5. Summary judgment was improper because a reasonable jury could find the elements of intentional interference and could reasonably disagree about whether Thompson's interference was legally justified or privileged.

Questions Presented

1. Whether the letters' statements concerning Armstrong were substantially true or nonactionable opinions, defeating his defamation claim.
2. Whether the letters satisfied the publicity and falsity requirements for false-light invasion of privacy.
3. Whether the letters satisfied the publicity requirement for publication of private facts.
4. Whether the evidence could support the extreme and outrageous conduct and severe emotional distress elements of intentional infliction of emotional distress.
5. Whether genuine issues of material fact existed regarding whether Thompson's interference with Armstrong's prospective employment was improper or legally justified under the Restatement seven-factor test.

Disposition

reversed_and_remanded