Appeals Court Upholds Dismissal of Former Dean's Libel Suit Against St. Cloud State Student Paper

On Jan. 25, 2008, a Minnesota Court of Appeals affirmed a lower court’s grant of summary judgment in a libel suit filed by a professor and former dean at St. Cloud State University, finding in favor of the university’s student newspaper, the University Chronicle.

According to the Student Press Law Center (SPLC), the suit, Lewis v. University Chronicle, 2008 Minn. App. Unpub. LEXIS 210 (Minn. Ct. App. Jan. 25, 2008) stemmed from an October 2003 Chronicle story in which a former student claimed to have been treated unfairly by then-dean Richard D. Lewis. In the story, former student Robbi Hoy, who had been involved in a dispute with Lewis, claimed she overheard Lewis making anti-Semitic remarks and racial slurs. After publication, Hoy told a Chronicle reporter that the remarks she heard came from another professor, not Lewis. The Chronicle printed a partial retraction of the story in November 2003, apologizing to Lewis.

Lewis originally filed a libel suit against St. Cloud State and the Minnesota State Colleges and University system in Ramsey County District Court, arguing the defendants were “vicariously liable” for the defamatory statements printed in the Chronicle because, Lewis claimed, they exercise control over the student newspaper’s operations. The district court dismissed the case, and the Minnesota Court of Appeals upheld the district court’s dismissal in June 2004.

The court of appeals found in Lewis v. St. Cloud State University, 693 N.W. 2d 466 (Minn. Ct. App. 2005) that the university and the state system could not be held liable for what an autonomous student newspaper prints. A spokeswoman for the Minnesota state university system told the SPLC in 2005 that the policy in place at the school specifies that the student newspaper is editorially independent from the university and the university and its officials cannot control what the newspaper prints.

According to the appeals court’s 2004 ruling, “[The school’s] relationship with the Chronicle, is, by virtue of [the university system’s] policy and First Amendment constraints, significantly different from a private publisher’s relationship with its newspaper,” the court said. “Respondents, unlike a private publisher, have no control over the content of the Chronicle.”

After the Minnesota State Supreme Court declined to hear Lewis’ appeal in his suit against the university and the state university system, he filed a libel suit against the Chronicle in Stearns County District Court.

The Stearns County District Court granted summary judgment to the Chronicle in March 2005, ruling that Lewis could not meet the burden of proof as a “limited-purpose public figure.” In order to succeed on a libel claim, a public figure must prove that the alleged defamatory statements were made with “actual malice”: knowledge of the statements’ falsity or a reckless disregard for whether they are true or not. The January 25 court of appeals decision affirmed this ruling.

– Patrick File
Silha Fellow and Bulletin Editor



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