Santillo v. Reedel
634 A.2d 264, 22 Media L. Rep. (BNA) 1381, 430 Pa. Super. 290 (1993)
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Rule of Law:
Information regarding a political candidate's past conduct, particularly when it involves an official complaint of potential criminal behavior, is a matter of legitimate public concern and its disclosure is not an invasion of privacy. Furthermore, a claim for false light invasion of privacy cannot succeed if the statements made are factually true and do not create a false impression through selective or misleading publication.
Facts:
- Eight years prior to 1987, Sandra Adams filed a formal police complaint alleging that appellant, then a police officer, had made unwanted sexual advances toward her sixteen-year-old daughter.
- The police investigated the complaint, during which the daughter took a polygraph test that indicated she was being truthful.
- Adams signed a release agreeing not to press criminal or civil charges on the condition that appellant resign from the police force.
- One week after the release was signed, appellant resigned from his position as a police officer.
- In 1987, appellant ran for the office of district justice in Montgomery County.
- During the election campaign, reporters questioned Chief of Police Clement Reedel and Lieutenant Robert Piermatteo about the old complaint.
- Reedel and Piermatteo confirmed to the press that Adams had made a complaint and that a polygraph test had been administered, but they did not reveal the nature or findings of the investigation.
Procedural Posture:
- Appellant sued Chief Reedel, Lieutenant Piermatteo, and others in a state trial court for defamation, invasion of privacy, and intentional infliction of emotional distress.
- After preliminary discovery, Reedel and Piermatteo filed a motion for summary judgment.
- The trial court granted the motion for summary judgment, dismissing all claims against Reedel and Piermatteo.
- Appellant, the plaintiff at trial, appealed the trial court's grant of summary judgment to the Superior Court of Pennsylvania.
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Issue:
Do police officials commit an invasion of privacy, either by giving publicity to private life or placing a person in a false light, when they confirm to the press the existence of a past complaint and investigation concerning a candidate for public office?
Opinions:
Majority - Judge Beck
No. Police officials do not commit invasion of privacy by confirming such information because a political candidate's past conduct is a matter of legitimate public concern, and confirming true facts without misleading embellishment does not constitute placing someone in a false light. The court reasoned that for a 'publicity to private life' claim to succeed, the information must not be of legitimate public concern. As appellant was a candidate for district justice, a position of public trust, a prior complaint alleging he violated the law was relevant, newsworthy, and a matter of legitimate concern for voters, thus defeating the claim. For the 'false light' claim, the court found that the officials' statements were factually true—a complaint was made and an investigation occurred. The court rejected the argument that the officials created a false impression through 'discriminate publication,' finding they merely confirmed limited facts already known to reporters and did not selectively release information from the appellant's file to create a false narrative.
Analysis:
This decision reinforces the high bar for public figures, including political candidates, to succeed on invasion of privacy claims. It firmly establishes that a candidate's character and past conduct, especially when documented in official complaints, fall under the 'legitimate public concern' exception, significantly limiting their privacy rights. The ruling also narrowly construes the 'false light by implication' doctrine, protecting officials who provide limited, factually accurate confirmations to the media. This offers a degree of protection for public officials responding to press inquiries about matters of public interest, so long as their statements are true and not presented in a deliberately misleading manner.
