Renita Hill v. William Cosby, Jr.
665 F. App'x 169
3rd Cir.2016Background
- Renita Hill alleged Bill Cosby drugged and sexually assaulted her in the 1980s; she publicly disclosed her allegations in November 2014 after other accusers came forward.
- After Hill’s interview, Cosby (through his attorney), Cosby himself (Florida Today interview), and Camille Cosby (Washington Post letter) made public statements criticizing the accusers as uncorroborated, fantastical, or driven by media hysteria.
- Hill sued in Pennsylvania state court asserting defamation/defamation per se, false light, and intentional infliction of emotional distress (IIED); Cosby removed to federal court and moved to dismiss under Fed. R. Civ. P. 12(b)(6).
- The District Court dismissed Hill’s complaint with prejudice; the Third Circuit affirmed the dismissal.
- The Third Circuit reasoned that (1) Singer’s attorney statement disclosed the factual basis for the opinion that accusations were uncorroborated, (2) Cosby’s Florida Today remarks did not imply undisclosed defamatory facts, and (3) Camille Cosby’s letter did not specifically apply to Hill or imply particular undisclosed facts.
- Because none of the statements were capable of a defamatory meaning, Hill’s defamation claim failed; false light and IIED claims likewise failed as derivative or novel claims dependent on defamatory language.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Singer attorney statement was actionable defamation | Singer implied Hill lied/extorted; mixed opinion implying undisclosed false facts | Statement was opinion grounded on disclosed facts (timing, lack of contemporaneous reports) | Not actionable: factual bases disclosed; opinion protected |
| Whether Cosby’s Florida Today interview implied undisclosed defamatory facts | Phrases like “innuendos” amounted to accusing accusers of lying | Remarks invited public fact-checking and did not assert undisclosed facts | Not actionable: reasonable reader would not infer undisclosed defamatory facts |
| Whether Camille Cosby’s letter was defamatory as to Hill | Reference to poor "vetting" and UVA false-rape comparison implicated Hill specifically | Letter targeted media and defended husband; did not convey specific undisclosed facts about Hill | Not actionable: failed "of and concerning" and no implication of particular undisclosed facts |
| Whether false light / IIED survive absent defamatory finding | False light and IIED arise from defendants’ allegedly harmful statements | Claims depend on defamatory meaning; IIED novel in this context and not pleaded with actionable language | Dismissed: false light fails with defamation; IIED not allowed where language is not defamatory and claim would be novel |
Key Cases Cited
- Milkovich v. Lorain Journal Co., 497 U.S. 1 (opinion vs. provable false fact distinction)
- Gertz v. Robert Welch, Inc., 418 U.S. 323 (First Amendment protection for ideas and opinions)
- Remick v. Manfredy, 238 F.3d 248 (3d Cir.) (analysis of when statements are non-defamatory as a matter of law)
- Redco Corp. v. CBS, Inc., 758 F.2d 970 (3d Cir.) ("mixed" opinion and disclosure of factual basis)
- Tucker v. Fischbein, 237 F.3d 275 (3d Cir.) (defamation as state cause of action)