FAITH NEVINS HAWKS v. MICHAEL RUBY, ET AL.

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Torts — Defamation — Prima facie claim

This appeal concerns an article about appellant, Faith Nevins Hawks, that was published in The Country Chronicle (“The Chronicle”), a local newspaper distributed in northern Baltimore County. In the Circuit Court for Baltimore County, Nevins Hawks filed a defamation suit against appellees: Michael Ruby, editor and reporter for The Chronicle; Right Action Communications, LLC (“Right Action”), The Chronicle’s publisher; and Patricia Bentz, executive director of the Baltimore County Historic Trust, Inc., a/k/a the Preservation Alliance (“Preservation Alliance”), who was quoted in the article. The case was tried to a jury and, at the end of Nevins Hawks’s case-in-chief, the circuit court granted judgment in favor of Ruby, Right Action, and Bentz, ruling that Nevins Hawks failed to make out a prima facie case of defamation against appellees and, in the alternative, that Ruby and Right Action were protected by the fair reporting and fair comment privileges and had not abused those privileges. Nevins Hawks’s motion for a new trial was denied. Nevins Hawks presents two questions for our review, which we have rephrased:1 I. Did the trial court err by ruling that Nevins Hawks failed to adduce sufficient evidence to make out a prima facie claim of defamation against Bentz? II. Did the trial court err by ruling that Nevins Hawks failed to adduce sufficient evidence to make out a prima facie claim of defamation against Ruby and Right Action and, if so, did it also err by ruling that the statements in the article were privileged under the fair reporting and fair comment doctrines, and that Nevins Hawks failed to adduce evidence sufficient to overcome those privileges? For the following reasons, we …

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