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Keywords

tortdefendantdamagesprecedentappealtrialmotionsummary judgment

plaintiffdefendantappealtrialsummary judgmentappellantappellee

Related Cases

Yeager v. Local Union 20, Teamsters, Chauffeurs, Warehousemen, & Helpers of America, 6 Ohio St.3d 369, 453 N.E.2d 666, 116 Lab.Cas. P 56,408, 6 O.B.R. 421

Facts

The vice-president and general manager brought action against the local union and a chapter of dissident union members, claiming damages for defamation and other torts. The dispute arose from incidents involving picketing and handbilling, where the vice-president was described using derogatory terms. The trial court granted summary judgment for the defendants, leading to an appeal. The Supreme Court had to determine whether the actions were part of a labor dispute and whether the claims were actionable.

The record shows that there was evidence that the defendants did intentionally and maliciously express certain threats which put the plaintiff in fear and terror.

Issue

Whether the defendants' actions constituted a labor dispute and whether the claims for defamation, invasion of privacy, and intentional infliction of emotional distress were actionable.

The first issue before this court is whether summary judgment was properly granted upon the trial court's determination that the defendants-appellees' actions were conducted within the context of a labor dispute.

Rule

The term 'labor dispute' includes any controversy concerning terms, tenure or conditions of employment, and statements made in this context are protected under the 'actual malice' standard for defamation.

The term 'labor dispute' is defined in Section 152(9), Title 29, U.S. Code, as follows: 'The term ‘labor dispute’ includes any controversy concerning terms, tenure or conditions of employment, or concerning the association or representation of persons in negotiating, fixing, maintaining, changing, or seeking to arrange terms or conditions of employment, regardless of whether the disputants stand in the proximate relation of employer and employee.'

Analysis

The court determined that the actions taken by the defendants were indeed part of a labor dispute, thus protecting their speech under federal labor laws. The court applied the 'actual malice' standard to the defamation claim, concluding that the statements made were not actionable. Additionally, the court found that the invasion of privacy claim did not hold, as the language used was deemed opinion rather than fact. However, the court recognized the need to allow a cause of action for intentional infliction of emotional distress, overturning previous precedent.

Therefore, we believe that the court of appeals was correct in affirming the trial court because this is an issue for the court, not the jury, to decide and the record in the instant case convinces us that the activity alleged does constitute a labor dispute as defined by federal law.

Conclusion

The Supreme Court affirmed the lower court's judgment regarding defamation, invasion of privacy, and intentional interference with employment, but reversed the decision on the claim for intentional infliction of emotional distress, allowing that claim to proceed.

Based upon all of the foregoing, we affirm the judgment of the court of appeals in part with respect to appellant's causes of action for defamation, invasion of privacy and intentional interference with an employment relationship.

Who won?

The defendants prevailed in the case, as the court found their actions were protected under the context of a labor dispute and that the claims for defamation and invasion of privacy were not actionable.

The court found that the activity alleged does constitute a labor dispute as defined by federal law.

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