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CASE ENTRY

Horne v. WTVR, LLC

Job applicant divulges a 15-year-old nonviolent drug conviction (she says it was her roommate’s drugs, and she’s never had trouble since) to Prince George County, Va. school officials; they hire her to be budget director, a position that entails no direct contact with children. Oh no! Turns out the conviction disqualifies her; she’s fired. Local news runs a story that (though it doesn’t name her) implies she may have lied about her criminal history in her application. Defamation? The Fourth Circuit says nope, she’s a “public official,” and she didn’t prove the local news acted with “actual malice.”


Tags: 2018, Defamation, First Amendment, Fourth Circuit, Free Speech

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