Law School Case Brief
Haynes v. Alfred A. Knopf, Inc. (1993) - 8 F.3d 1222 (7th Cir. 1993)
The rule of substantial truth is based on a recognition that falsehoods which do no incremental damage to the plaintiff's reputation do not injure the only interest that the law of defamation protects. A news report that contains a false statement is actionable only when significantly greater opprobrium results from the report containing the falsehood than would result from the report without the falsehood. Even when the plaintiff in a defamation suit is not a public figure, the Supreme Court insists in the name of the First Amendment that unless the author is deliberately lying or is recklessly indifferent to the truth or falsity of what he says, neither is a plausible hypothesis here, the plaintiff must prove actual though not necessarily pecuniary harm in order to recover damages. Falsehoods that do not harm the plaintiff's reputation more than a full recital of the true facts about him would do are thus not actionable. The rule making substantial truth a complete defense and the constitutional limitations on defamation suits coincide.
Nicholas Lemann, a journalist, wrote a book entitled "The Promised Land: The Great Black Migration and How It Changed America," which Alfred A. Knopf, Inc. printed. The book discussed the life of one black woman who had married and later divorced the former husband. The book had statements from the woman that her former husband had left his children alone at night when he was supposed to be watching them, lost a job or jobs because of drinking, and spent money on a car that he should have used to buy shoes for his children. The former husband filed suit for defamation and invasion of privacy. The district court granted summary judgment to defendants
Did the publication of facts about the former husband constitute defamation and invasion of privacy?
The court held that the statements were not defamatory because these statements did not show the former husband in a worse light than a bare recitation of the uncontested facts about his behavior in relation to the woman and her children would have done and because the alleged falsehoods were merely illustrations of undoubted truths about the former husband's character at the time.
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