Lane Ellen Tollefsen v. Gregory L. Jantz
75117-4
| Wash. Ct. App. | Aug 7, 2017Background
- Plaintiff Lane Tollefsen was a long‑time sixth‑grade teacher at King’s Elementary (a CRISTA school); Dr. Gregory Jantz is a prominent CRISTA psychologist and author.
- In 2010 Tollefsen reported behavioral concerns about Dr. Jantz’s son Gregg; the school later removed Gregg from her class.
- In Oct. 2013 Jantz recounted an anecdote (on radio and in his book) that his son had seen boys take pills in front of a teacher; Tollefsen believed the anecdote referred to her.
- Tollefsen sued for defamation and outrage (intentional infliction of emotional distress), alleging the statements implied she administered medication (potentially criminal/school rule violations) and caused severe emotional distress.
- Jantz issued a clarification on radio (not naming Tollefsen) stating he believed medication was legally prescribed and parent‑authorized; he moved for summary judgment, which the trial court granted.
- The Court of Appeals affirmed, holding Tollefsen failed to raise a genuine factual dispute that the statements were capable of defamatory meaning or that Jantz’s conduct was extreme and outrageous.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Identification (Did statements concern Tollefsen?) | Audience (King’s community) could identify her from surrounding circumstances and prior dispute with Jantzes | Statements did not name or describe gender/school/year; identification not certain | Genuine issue of fact existed whether members of school community would identify Tollefsen |
| Falsity | Statements implied students took medicine in her classroom; she declares she never administered medication | Jantz: his son actually told him the story, so no showing of falsity | Genuine issue of material fact whether statements were false (i.e., implied in‑class administration) |
| Defamatory meaning (Were statements capable of harming reputation?) | Implication (illegal distribution of controlled substances or violation of school policy) would tend to harm reputation and expose her to discipline/criminal liability | Statements, when read in context (book, radio preface, clarification), imply legally prescribed, parent‑authorized administration; do not imply wrongdoing or policy violation | As a matter of law, statements were not capable of defamatory meaning; summary judgment for defendant affirmed |
| Outrage / IIED (Was conduct extreme and outrageous?) | Recounting (and possibly fabricating) the anecdote to sell books recklessly exposed her to discipline/criminal charges and caused severe emotional harm | Including a classroom anecdote in book/radio about a son’s story is not beyond all bounds of decency; clarification mitigates harm | No reasonable jury could find Jantz’s conduct extreme/outrageous; summary judgment for defendant affirmed |
Key Cases Cited
- Young v. Key Pharm., 112 Wn.2d 216 (trial‑court summary judgment burden allocation)
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden shifting)
- Sims v. KIRO, Inc., 20 Wn. App. 229 (identification requirement for defamation)
- Mohr v. Grant, 153 Wn.2d 812 (elements of defamation and evidentiary standards)
- Schmalenberg v. Tacoma News, Inc., 87 Wn. App. 579 (falsity by implication)
- Ernst Home Ctr., Inc. v. United Food & Commercial Workers, 77 Wn. App. 33 (statements capable of defamatory meaning)
- Crossman v. The Brick Tavern, Inc., 33 Wn. App. 503 (use of extrinsic evidence to show defamatory application)
- Herron v. KING Broad. Co., 112 Wn.2d 762 (defamation by implication)
- Kloepfel v. Bokor, 149 Wn.2d 192 (elements of outrage/IIED)
- Grimsby v. Samson, 85 Wn.2d 52 (extreme and outrageous conduct standard)
- Beaupre v. Pierce County, 161 Wn.2d 568 (appellate review of summary judgment)
- LaMon v. Butler, 112 Wn.2d 193 (appellate affirmance on any supported basis)