Law School Case Brief
Santillo v. Reedel - 430 Pa. Super. 290, 634 A.2d 264 (1993)
A false light claim can be established where true information is released if the information tends to imply falsehoods. Literal accuracy of separate statements will not render a communication "true" where the implication of the communication as a whole was false. In order to prevail on this theory of false light invasion of privacy, a plaintiff must show discriminate publication of true statements, that is, defendant must have created a false impression by knowingly or recklessly publicizing selective pieces of true information. The question is whether a defendant made discrete presentations of information in a fashion, which rendered the publication susceptible to inferences casting the plaintiff in a false light.
In 1987, plaintiff Michael Santillo, a former police officer, ran for the office of district justice in Montgomery County. Prior to the election, a young woman informed the press that eight years before, when she was sixteen years old, Santillo made unwanted sexual advances toward her. The newspaper articles revealed that defendant Sandra Adams, the girl's mother, made a formal complaint to the police department and sought to press charges against Santillo. The police began an investigation of the complaint and interviewed the alleged victim. She was given a polygraph test that indicated that she was telling the truth. In response to questions by newspaper reporters, defendants Clement Reedel and Robert Piermatteo, who were police officials, confirmed that a complaint had been made by Adams and that a polygraph test had been administered in the investigation of the complaint. After some discussion with the police, Adams signed a release stating that she would not press criminal charges nor bring a civil action against Santillo provided he resigned from the police force. One week after Adams signed the release, Santillo resigned from his position as a police officer. Thereafter, Santillo filed a lawsuit Pennsylvania state court against the publishers of the newspapers, the reporters, Adams and her daughter and Reedel and Piermatteo for defamation, invasion of privacy and intentional infliction of emotional distress, seeking both compensatory and punitive damages. The parties filed Answers denying the allegations and after some preliminary discovery, Reedel and Piermatteo filed a motion for summary judgment, which was granted. Santillo appealed that judgment.
Did the trial court err by granting Reedel and Piermatteo summary judgment?
The court affirmed the trial court's order, which granted summary judgment to Reedel and Piermatteo, noting that the matter was of legitimate public concern in light of Santillo's candidacy. Moreover, the court noted that no statement made by Reedel and Piermatteo with regard to the matter was false and that they did not selectively publicize adverse portions of Santillo's personnel file so as to create a false impression of him.
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