Noonan v. Staples
First Circuit Decision in Noonan v. Staples on Truth as a defense for libel
SUMMARY: Staples fired sales director Alan S. Noonan was fired for padding his expense report. Executive Vice President Jay Baitler sent an e-mail to approximately 1,500 employees explaining the reason for the firing.
The e-mail contained no untruths, but Mr. Noonan sued for defamation anyhow.
Unfortunately for Staples, truth is not a defense in Massachusetts if the challenged statement was communicated with actual malice according to the 1st U.S. Circuit Court of Appeals in its recent decision Noonan v. Staples.
The 1st U.S. Circuit Court of Appeals looked at G. L. c. 231, Section 92, which says that truth is a defense to libel "unless actual malice is proved." However, in a 1998 case, Shaari v. Harvard Student Agencies, the Supreme Judicial Court ruled that statute unconstitutional as applied to matters of public concern.
DOCUMENT INFO
Doc Type:
Decision
Filed: 2/13/2009
Legal Document Name:
Noonan v. Staples
First Circuit Decision in Noonan v. Staples on Truth as a defense for libel
Jurisdiction: Federal, 1st Circuit, Massachusetts
Legal System: United States
Communications & Media Law
Business Torts
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