This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case involves a long-standing personal and professional feud between two academics, both holding doctorate degrees. The Plaintiff criticized the Defendant's anthropological findings on the Huichol Indians, leading to mutual efforts to discredit each other's reputations. The Plaintiff alleged defamation based on derogatory statements made by the Defendant and claimed tortious interference with a publishing contract after the Defendant threatened legal action against the Plaintiff's publisher, resulting in the cancellation of the book's publication (paras 1-4).
Procedural History
- District Court of Santa Fe County: Granted summary judgment in favor of the Defendant on all counts, including defamation and tortious interference with contract (para 5).
Parties' Submissions
- Plaintiff-Appellant: Argued that the Defendant's defamatory statements harmed his reputation and career, and that the Defendant's letter to the publisher constituted tortious interference with contract (paras 5, 45-46).
- Defendant-Appellee: Contended that many of the alleged defamatory statements were time-barred, were non-actionable opinions, or lacked evidence of publication. Also argued that the letter to the publisher was a legitimate legal threat and did not cause the publisher's decision to cancel the book (paras 7-13, 45-47).
Legal Issues
- Whether the alleged defamatory statements were actionable under the law of defamation.
- Whether the Plaintiff's defamation claims were barred by the statute of limitations.
- Whether the Defendant's actions constituted tortious interference with the Plaintiff's publishing contract.
Disposition
- The Court of Appeals affirmed in part and reversed in part the district court's decision:
- Affirmed summary judgment for the Defendant on most of the defamation claims.
- Reversed summary judgment for the Defendant on certain defamatory statements and the tortious interference with contract claim (paras 48-49).
Reasons
Per Robinson J. (Sutin and Fry JJ. concurring):
Defamation Claims: The Court analyzed each alleged defamatory statement to determine whether it was actionable. Statements such as calling the Plaintiff a "lousy anthropologist" and describing him as "paranoid" were deemed non-actionable opinions. However, statements implying factual assertions, such as the Plaintiff being "unqualified" for a project and the University of Michigan "disowning" him, were found to be potentially defamatory and should be decided by a jury (paras 24-43).
Statute of Limitations: The Court held that several statements were time-barred because they were made outside the three-year limitation period. However, some statements, including those made within three years of the amended complaint, were not time-barred and could proceed (paras 7-13).
Tortious Interference with Contract: The Court found that there was sufficient evidence to raise a genuine issue of material fact regarding the Defendant's intent in writing the letter to the publisher. The Plaintiff presented evidence suggesting the Defendant's motive was to harm him rather than to protect his own reputation. The Court also found that the letter could have caused the publisher to cancel the book, warranting further proceedings on this claim (paras 45-47).
Conclusion: The Court remanded the case for further proceedings on the actionable defamation claims and the tortious interference with contract claim (paras 48-49).