Giles v. Heyward
315 Ga. App. 409
Ga. Ct. App.2012Background
- Heyward, a church deacon, sued Giles for defamation (slander per se) based on accusations of adultery and attempted theft.
- A jury awarded Heyward $125,000 in damages; judgment entered, Giles appeals.
- During a Mt. Carmel Baptist Church meeting, Giles read a written declaration accusing Heyward of crimes; contemporaries testified the accusations were false.
- Giles argued the case involved church governance and violated separation of church and state; court rejected this to the extent it involved defamation of non-ecclesiastical conduct.
- The trial court denied Giles’s directed-verdict motion; evidence supported the jury’s findings, and the court instructed on privileged communications.
- The appellate court affirmed the verdict, holding damages supported by the evidence and no reversible error in jury instructions or evidentiary rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction over ecclesiastical matters | Giles: church governance issues barred civil court jurisdiction | Heyward: defamation based on crimes is not ecclesiastical | Civil court may hear defamation not involving ecclesiastical doctrine |
| Directed verdict standard | Giles: evidence compels verdict in his favor | Heyward: evidence supports denial of directed verdict | Any evidence supports denial; verdict not against weight of evidence |
| Admission of lunch-recess testimony | Giles: trial court excluded evidence of tampering during recess | Heyward: no ruling on admissibility was shown; evidence irrelevant | No preserved ruling; even if admitted, evidence unlikely relevant; no error |
| Jury instruction on privileged statements | Giles: requested charge on privilege should have been given | Trial court charged on privilege; substantial coverage | Charge sufficiently covered privilege; refusal not harmful error |
| Damages for slander per se | Heyward suffered general damages; jury award proper | Challenge to amount | Damages supported; award not clearly excessive |
Key Cases Cited
- First United Church v. Udofia, 223 Ga.App. 849 (1996) (separation of church and state does not bar all ecclesiastical disputes; defamation exception for crimes)
- Horne v. Andrews, 264 Ga.App. 145 (2003) (courts may address disputes in an ecclesiastical context if no doctrinal inquiry required)
- Sagon v. Peachtree Cardiovascular & Thoracic Surgeons, 297 Ga.App. 379 (2009) (appellate review of verdicts; weight of evidence for jury credibility notes)
- Riddle v. Golden Isles Broadcasting, 292 Ga.App. 888 (2008) (general damages for slander per se presumed by law)
- Turnage v. Kasper, 307 Ga.App. 172 (2010) (denial of directed verdict affirmed where evidence supports claim)
- Bennett v. Moore, 312 Ga.App. 445 (2011) (evaluation of jury charge sufficiency; harmful error standard)
- Columbia County v. Doolittle, 270 Ga. 490 (1999) (any evidence standard for directed verdict analysis)