Reader's Digest Assn. v. Superior Court
690 P.2d 610, 37 Cal.3d 244, 208 Cal. Rptr. 137 (1984)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A public figure plaintiff in a defamation action cannot defeat a defendant's summary judgment motion without presenting clear and convincing evidence that would allow a trier of fact to find the defendant published the challenged statements with actual malice—that is, with knowledge of their falsity or with reckless disregard for their truth.
Facts:
- Synanon was founded in 1958 by Charles Dederich as a drug rehabilitation program.
- Over time, Synanon evolved into an alternative lifestyle community, began calling itself a church, and became the subject of public controversy.
- David and Cathy Mitchell, publishers of the Point Reyes Light, wrote a series of articles critical of Synanon, for which they won a Pulitzer Prize.
- David MacDonald, a writer for Reader’s Digest, authored an article for the July 1981 edition titled 'The Little Paper That Dared,' which described the Mitchells' work and was critical of Synanon.
- MacDonald based his article on the Mitchells' reporting, research papers by University of California professor Richard Ofshe, and conversations with the Mitchells and Ofshe.
- The article accused Synanon of intimidation and violence, including a rattlesnake attack on an attorney for which Dederich and other members were convicted.
- Synanon's lawsuit focused on three sentences in the article: 'Though his spectacular claims of success were never proved...' and 'Since 1968, minimal drug rehabilitation work had been attempted; funds, however, were still solicited on that basis.'
Procedural Posture:
- The Synanon Church and Charles Dederich filed a lawsuit for libel and other claims against Reader's Digest Association, Inc., David MacDonald, and others in the Marin County Superior Court (trial court).
- Reader's Digest and MacDonald moved for summary judgment, arguing that the plaintiffs were public figures and could not prove the statements were made with actual malice.
- The trial court denied the motion for summary judgment.
- Reader's Digest and MacDonald (petitioners) then sought a writ of mandate from the California Supreme Court to compel the trial court to vacate its denial and grant the summary judgment motion.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a public figure plaintiff in a defamation action raise a triable issue of fact as to actual malice sufficient to defeat a summary judgment motion when the publisher relied on reputable sources and the allegedly defamatory statements were rational interpretations of the available information?
Opinions:
Majority - Broussard, Acting C. J.
No. A public figure plaintiff fails to raise a triable issue of fact as to actual malice where the evidence shows the publisher relied on reputable sources and exercised a reasonable degree of literary license in characterizing the underlying information. First, the court determined that Synanon and Dederich are limited-purpose public figures because they voluntarily thrust themselves into the public spotlight through massive publicity campaigns over many years, thereby gaining access to the media to counter criticism and accepting a greater risk of public scrutiny. As public figures, they must prove by clear and convincing evidence that Reader's Digest published the statements with 'actual malice'—knowledge of falsity or reckless disregard for the truth. The court found no such evidence. Reader's Digest and MacDonald relied on reputable sources: Pulitzer Prize-winning journalists and a university professor. Reliance on such sources, absent obvious reasons to doubt their veracity, does not require a publisher to conduct an independent investigation. Furthermore, the court found that the challenged statements fell within the protected bounds of 'literary license.' The characterization of Synanon's claims as 'spectacular' and 'never proved' was a rational interpretation of the source materials and Synanon's own conflicting public statements. Similarly, describing the post-1968 rehabilitation efforts as 'minimal' was a supportable interpretation based on the sources' information and Dederich's own admissions that the organization's focus had shifted. Because plaintiffs failed to provide clear and convincing evidence that the defendants entertained serious doubts about the truth of the publication, there is no triable issue of fact, and summary judgment is appropriate.
Analysis:
This decision reinforces summary judgment as a 'favored' tool in public figure defamation cases to protect First Amendment rights from the chilling effect of protracted litigation. It clarifies that the 'actual malice' standard requires a plaintiff to produce substantial evidence of the defendant's subjective state of mind, specifically that the defendant entertained serious doubts about the truth of the publication. The court's explicit endorsement of 'literary license' provides publishers with crucial breathing space, allowing them to interpret and characterize events using their own language, so long as the interpretation is a rational one based on their sources. This precedent makes it significantly more difficult for public figures to proceed to trial by merely 'quibbling' over word choices or alleging a publisher's failure to be perfectly objective.
