Stanton v. Metro Corporation

Rule of Law:

A publication may be reasonably susceptible to a defamatory meaning, even if it includes a disclaimer, if the disclaimer's placement, size, and the overall context could cause a considerable and respectable segment of the community to overlook it and mistakenly associate the plaintiff with the defamatory content.

Facts:

• Metro Corp. published an issue of Boston magazine in May 2003 containing an article titled “The Mating Habits of the Suburban High School Teenager.”
• The cover referred to the article with the phrase, “Fast Times at Silver Lake High: Teen Sex in the Suburbs.”
• The article began with a large photograph featuring Stacy Stanton, a high school student, taken at a school dance.
• In the photograph, Stanton is formally dressed and smiling at the camera, while other students are depicted smoking or holding cups.
• The article's text described a trend of increased sexual promiscuity among local teenagers.
• On the same page as Stanton's photograph, a disclaimer was printed in small, italicized font stating, “The individuals pictured are unrelated to the people or events described in this story.”
• The disclaimer also asserted the photos were from a “project on teen sexuality,” a project in which Stanton alleges she never participated.

Procedural Posture:

• Stacy Stanton sued Metro Corp. in Massachusetts state court for defamation and invasion of privacy.
• Metro Corp., the defendant, removed the case to the U.S. District Court for the District of Massachusetts based on diversity of citizenship.
• The defendant, Metro Corp., filed a motion to dismiss the complaint for failure to state a claim.
• The U.S. District Court (trial court) granted the motion to dismiss, ruling that the publication was not defamatory as a matter of law due to the presence of a disclaimer.
• Stacy Stanton, as appellant, appealed the dismissal of her defamation claim to the U.S. Court of Appeals for the First Circuit.