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Le Marc's Management Corp. v. Valentin
709 A.2d 1222
Md.
1998
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*1 et al. MANAGEMENT CORPORATION LE MARC’S Francisco VALENTIN. Term, 129, Sept. 1996.

No. Maryland. Appeals Court 19,May 1998. *2 Columbia, DeGeorge,

Michael P. for appellant. Sutter, brief), (Hopkins Washington, Charles M. Tobin & on DC, for appellee. BELL, C.J., ELDRIDGE, RODOWSKY,

Argued before CHASANOW, JJ., WILNER, RAKER and and ROBERT L. KARWACKI, (retired), Judge Specially Assigned.

ELDRIDGE, Judge. standard, appropriate Mary- This case concerns the under law, punitive damages land common for the allowance of defamation actions. Valentin,

In late 1987 Francisco having lived all but the first Rico, of life in to year City his Puerto moved New York hopes improving mastery English his limited lan job He immedi guage opportunities. search better to as a room clerk at Fifth ately went work stock Le Marc’s Cards, Inc., a Hallmark card Le Avenue store owned Management May In and other Corp.1 Marc’s Valentin- corporations collectively 1. Hereafter we refer to both as “Le shall Marc’s.” given polygraph at the tests employees store were Hispanic or knew of any employees stealing of the were determine reported The examiner occurring. polygraph thefts were administrator, Sauer, that he corporate Le Marc’s to Robert information,” but it holding “was back believed that Valentin polygraph results because interpret was difficult to “language barrier.” 6,1988, he submitted a letter testified that on June

Valentin from to and received a letter of recommendation resignation resignation letter of manager, original his John Cefai. His and, apparently, not introduced into evidence has never been found. Sauer testified that it was not Valentin’s file, and testified that he did not make a personnel Valentin for his copy the letter records. Valentin further testified leaving that the letter stated that he was Le Marc’s because planning Maryland pursue college he was to move to education.

Once relocated to Maryland, employed Valentin he was as July sales trainee at a furniture store until 1989 when he for applied and was hired as a teller-trainee for Sovran Bank. permission, With Valentin’s the Bank mailed reference re- quests employers. Upon receipt to his former Le Marc’s request, computer Sauer consulted his and re- database turned the reference form Bank stating that Valentin was “terminated due to pilferage.” placed The Bank then Valentin on him suspension days and told that he had four to clear his permanently job. record or he would lose his immediately telephoned explained

Valentin Sauer and his dilemma. promised investigate Sauer to the matter and to call immediately the Bank if he discovered that was an there in following day, error the reference. The Valentin traveled to New York order to meet with Sauer in person. Upon him, learning that was to waiting Valentin see Sauer testified that he employment read Valentin’s file and determined that Valentin had not for pilfering been terminated and that the original reference in error. that explained

Sauer then met with Valentin there was not a of his letter in his and asked him if copy resignation file ques- he had a Sauer also testified that Valentin was copy. not, Marc’s, Le during tioned about whether or his tenure with knowledge employees stealing. he had actual that other were employee Sauer was concerned about Valentin’s file were notes that personnel thefts because Valentin’s indeed, had, that he some of his suspected Valentin told Cefai employees stealing fellow were merchandise. Sauer then left document, room, drafted a and when he returned he him sign it to asked to it. The document presented Valentin that, language indicating per- included while Valentin never merchandise, other sonally employees stole he later discovered say anything my and that he “did not want to stealing were ... manager signed about Valentin [this] situation[ ].” document, would then call and write a believing Sauer clearing letter to the Bank his name. telephoned spoke

Sauer testified that he the Bank and in the Bank’s he also Balog personnel department; Sheila correcting original sent the Bank a letter testified he erroneous reference to which he attached the above described sent, to correct purporting document. The letter Sauer reference, “Thus Francisco’s pertinent part: the first stated to human incorrectly reason for termination was stated due file on Francisco does not reflect a physical error. Our pilferage directly situation with him. Please strike from the record this reason termination.” Balog any testified that she had no recollection of conversa- Sauer, specific tion with nor did she remember Valentin’s however, did that the statements testify, situation. She letter and the attached document did not clear Valentin’s Rather, testified, the attached name. she the letter and *4 “credibility,” on indicated that document cast doubt Valentin’s told the Bank a “covering [something] up,” he was and had “half truth.” for September

On the Bank terminated Valentin and that he falsifying employment application his indicated ineligible employment. was for future in filed this defamation action Valentín August On Le Montgomery County against Marc’s for the Circuit Court Cards, Inc. Fifth Avenue Corp. and Le Marc’s Management May jury in 1993. The found jury before a The case was tried $25,000 him in com- and awarded was defamed that Valentin $130,000 damages. Le damages punitive and pensatory verdict, notwithstanding a judgment motions for Marc’s filed trial, filed a motion for a new and remittitur. Valentin new except The trial court denied all the motions trial. remittitur, for judgment entered Valentine’s favor and $75,000 $25,000 damages. compensatory damages punitive and unreported opinion Both an the Court parties appealed, compensatory damages, affirmed the but Special Appeals award. The basis of the rever- punitive damages vacated the trial court to instruct the properly sal was the failure of the proof any punitive damages the standard of jury filed convincing parties is clear and evidence. Both award certiorari, for a writ of which we denied. petitions punitive dam- solely The case was retried on the issue the standard of jury properly The informed that ages. is clear and allowability punitive damages for the proof alia, received, The inter convincing jury evidence. also following instruction: exists, one, making when the the statement person

“Malice deliberately lies makes the statement truth or disregard that it is false or with reckless as its or, two, had person making when the the statement accuracy an obvious reason to distrust either the person or the source from which the learned statement or, three, finally, item when the statement is the statement inherently improb- it or is so person making invented write, print person say, able that a reckless would it.” an award of for Valentin jury

The returned $700,000.2 amount of The trial court denied Le Marc’s given jury 2. The verdict sheet stated as follows: *5 650 verdict, notwithstanding a a new trial judgment

motions for timely appeal. Le Marc’s filed a notice of and remittitur. by Special Prior to consideration of the case the Court of Appeals, we issued a writ of certiorari. trial court’s argues jury

Le Marc’s that the instruction under a no permitted punitive damages the award of standard law. it asserts longer Maryland Specifically, consistent with does not meet the standard above-quoted that the instruction Owens- set forth in allowability punitive damages for the Zenobia, (1992), Illinois v. and its 633 argues proper that the progeny. surprisingly, Not Valentin maintains that the trial court’s in- standard was used. He struction consistent with the standard set forth our prior opinions in defamation cases. Sullivan,

In New Times York Co. 84 U.S. S.Ct. and Curtis Co. v. (1964), Publishing L.Ed.2d 686 Butts, (1967), 18 L.Ed.2d 1094 the 388 U.S. 87 S.Ct. prohibits the First Amendment a Supreme Court held for a public figure recovering damages official or from public establishes, first defamatory plaintiff by falsehood unless evidence, that the defendant with convincing clear and acted malice,” “knowledge as it was false or “actual defined In disregard with of whether it was false or not.” reckless Welch, Inc., Gertz v. Robert 418 U.S. S.Ct. (1974), involving a case a private L.Ed.2d 789 defamation defendant, concern, a and a matter of plaintiff, public media that, action, an Supreme Court held such the First plaintiff proven by you find that the has actual malice clear "One: Do convincing had actual and evidence that defendants disregard yes a reckless for the truth? Either or no. If no, your you completed your answer is then have deliberations. If question your yes, proceed to two. answer is you punitive damages plaintiff? Question Two: Do award Either yes, you yes your enter below the sum which or no. If answer award. by Question of the defendants characterized Three: Was the conduct ill-will, yes convincing spite and evidence of or hatred? either clear no.” jury questions and the The answered the first two in the affirmative negative. question in the third compensatory precluded recovery Amendment negligence. The Court plaintiff at least established unless punitive damages that, in order to be entitled held further clear convinc- case, prove, must in such evidence, were made defamatory statements ing made with it defined as statements malice” which “actual *6 disregard of falsity with reckless of the or knowledge actual the truth. thereafter, this Court shortly decided

In a series of cases law, alia, that, in inter Maryland a common held as matter of action, party’s status or regardless of a defamation any if the matter, allowable damages are subject punitive made with statement was proves defamatory plaintiff for the disregard or knowledge of its with reckless ill-will, spite, malice in the sense We held that actual truth. support an hatred, injure, not suffice to to would intent action. See any in defamation punitive award (1978); Franchino, 131, A.2d 283 387 1129 v. Md. Marchesi 165, Piskor, 175, A.2d 352 v. 277 Md. Corp. Motors General 580, Sindorf, 276 Md. 350 810, (1976); Sales Co. v. 817 Jacron Matusevitch, (1976).3 347 Md. also A.2d 688 See Telnikoff (1997), 591-595, 230, the above- 561, A.2d 244-247 where 702 cases detail. cited are reviewed Zenobia, Md. 325 supra, in Owens-Illinois v. Subsequently, 652, on liability action based products 601 at at A.2d (Second) § 402A of Restatement liability and strict only be Torts, damages may generally punitive we held that defendant’s has established plaintiff awarded “the motive, ill- injure, intent by evil to conduct was characterized ” i.e., Furthermore, held will, fraud, we ‘actual malice.’ that, product in a punitive damages be recoverable clear and action, prove, by liability required evidence, had that the actual convincing defendant that, “armed this actual product defect in the Piskor, Marchesi, opinions, light it is clear In and Jacron 3. on the sheet in Question not have included verdict Three should been the case at bar. knowledge, the defendant consciously or deliberately disre- garded the potential harm to consumers.” 325 Md. at A.2d at 654. Zenobia,

Following this Court has consistently required that punitive damages only be awarded based on the defendant’s Thus, conscious wrongdoing. Wilson, Montgomery Ward v. (1995), Md. 664 A.2d involving punitive damages malicious prosecution and imprisonment false ac- tions, we stated that

“in a number of recent decisions this Court has clarified and modified the standards for the allowability dam ages tort cases. With respect to both intentional and torts, non-intentional we have held that an award of punitive damages generally must upon malice, be based actual in the sense of conscious and deliberate wrongdoing, evil or wrong motive, ful will, intent to injure, See, ill or fraud. e.g., Ellerin v. 337 Md. Savings, 652 A.2d 1117 Fairfax (1995); Komornik v. Sparks, (1993); Zenobia, Owens-Illinois v. supra, 325 Md. at *7 454, 601 A.2d at Evander, 649-650. See also Alexander v. 635, (1994).” 336 Md. 650 A.2d 260 also, Jenkins, See e.g., Scott 21, v. 345 Md. 690 A.2d 1000 (1997) (battery arrest); and Asner, false ACandS v. 344 Md. 155, (1996) 686 A.2d 250 (product liability); v. Owens-Corning Garrett, 500, (1996) 343 Md. 682 A.2d 1143 (negligence and Godwin, strict liability); ACandS v. 334, 340 Md. 667 A.2d 116 (1995) (product liability); Gypsum Baltimore, U.S. v. 336 Md. 145, (1994) 647 A.2d 405 (product liability).

While none of the above-cited cases specifically involved defamation, we have repeatedly stated actions, that in all tort “ an punitive award of damages must be based upon ‘conscious and deliberate wrongdoing, evil or wrongful motive, intent to ” will, injure, fraud,’ ill Jenkins, Scott v. supra, 345 Md. at 33, 1006, 690 A.2d at quoting Wilson, Montgomery Ward v. supra, 733, 339 Md. at 664 A.2d at 932. “Maryland law has limited the availability of punitive damages to situations which the defendant’s conduct is characterized knowing Savings, 337 v. wrongdoing,” Ellerin and deliberate Fairfax (1995). See also Komornik A.2d Md. 732-739, 629 A.2d at 727-731 Md. at supra, 331 Sparks, v. (Chasanow, J., concurring). decisions, punitive under our recent

Consequently, by clear plaintiff proves, if the may only be awarded damages requisite evidence, had the that the defendant convincing and i.e., an rea, support to such award. knowledge, mens actual opinions the to defamation recent Applying principle the damages are punitive to conclusion that leads the actions plaintiff the establishes in such actions when allowable defamatory that the had actual that the defendant statement was false.4 pertinent which is most opinion

The Court’s recent 337 Md. Savings, supra, present case is Ellerin Fairfax for the involving appropriate the standard damages in actions fraud deceit. allowance the in Ellerin with an examination of analysis our began We action, to determine of a fraud or deceit order elements was, indeed, the tort. The malice an element of requisite (337 1123, quoting at 652 A.2d at Nails opinion stated Md. (1994)): v. S & R, 398, 415-416, A.2d 668-669 “ in an action for fraud or ‘In order to recover (1) deceit, made a plaintiff prove must that defendant (2) plaintiff, its representation to the false representation either known the defendant or (3) truth, as to was made with reckless indifference its for the of defraud- misrepresentation purpose was made (4) ing misrepre- that the relied on the plaintiff, plaintiff (5) it, right rely on and that the sentation had injury resulting from the compensable suffered ” misrepresentation.’ *8 note, cases, 4. as we have in several that "actual ... does We Zenobia, wilful to know.” v. 325 Md. include the refusal Owens-Illinois 633, (1992). explanation an 462 n. A.2d n. 23 For McCallum, 451, 458-461, concept, very this limited see State J., (1991) (Chasanow, concurring). 253-255 Focusing our attention element, on the that, second we held although a defendant may be liable for compensatory damages if the above elements proven, are the defendant will not per se subject be punitive damages. Specifically, the Court held that punitive damages a deceit action may only be awarded proves that the defendant had actual knowledge falsity. pointed We out Ellerin that a representation made with “reckless indifference” as to the truth “does not mean actual knowledge of the falsity.” 337 Md. at Rather, A.2d at 1126. “reckless indifference” in the context of a deceit action means the defendant’s making a statement with the knowledge that he or she does not know whether it is true words, false. In other the defendant has actual knowledge that he or she did not know whether the statement was true false, but, with reckless truth, indifference to the made the statement with the intent of deceiving the Therefore, listener. while “reckless indifference” does encompass a level of actual knowledge, it is not a level sufficient to satisfy the actual knowledge of falsity required damages. The “ Court concluded in Ellerin that ‘reckless disregard’ or ‘reck- less indifference’ concerning the truth of the representation falls short of the mens rea which required is to support an award of punitive damages.” 337 Md. at 652 A.2d at 1126.

It is clear that holding supports Ellerin actual knowledge of the falsity as the sole standard for the award of punitive damages in defamation cases as well. Like fraud or actions, deceit the tort of defamation requires the plaintiff to prove that the defendant’s statement was false. But alternate standard heretofore applied for punitive cases, defamation namely disregard” truth, “reckless for the greater no than the level of required scienter by the “reckless indifference” rejected standard in Ellerin.

In St. Amant v. Thompson, 390 U.S. 88 S.Ct. (1968), L.Ed.2d 262 the Supreme held, alia, Court inter certain statements made public about a official were not made with a “reckless disregard” for the truth. While the Court made clear that “reckless disregard” must be determined on a

655 regarding the defini basis, give did guidance case it by case the defendant It stated disregard.” tion of “reckless “ ‘high degree with a the false statement must have made ... entertained serious falsity’ [or] of ... probable awareness at 88 publication. the 390 U.S. to truth” of doubts as the v. Louisi at Garrison quoting L.Ed.2d at S.Ct. 209, 216, 64, 74, 13 L.Ed.2d ana, 85 S.Ct. 379 U.S. Inc., 501 (1964). Magazine, v. New Yorker See also Masson (1991); 2419, 2430, 115 L.Ed.2d 447 496, 510, 111 S.Ct. U.S. Communications, Connaughton, Inc. v. Harte-Hanks (1989); 2678, 2686, 105 L.Ed.2d 562 657, 667, 109 S.Ct. U.S. States, 466 U.S. United Corp. v. Union the Bose Consumers (1984). 485, 503, 104 L.Ed.2d 502 S.Ct. nor doubts” “awareness serious Neither “entertainment mens rea of actual falsity” approaches the probable of ... such a standard Arguably, in Ellerin. knowledge required reject- there “reckless indifference” standard falls short of the however, disregard,” as defined clear, that “reckless ed. It is above, of mens encom- surpass not the level rea certainly does Thus, as matter by indifference.” passed “reckless law, rejected must disregard” be Maryland common “reckless punitive damages award of defamation as a standard for the cases. to the jury was not instructed as properly

Because the allowability punitive damages for defamation basis the cases, and judgment punitive damages the for we shall vacate punitive damages on the issue. remand a new trial Marc’s was insufficient evidence Le also contends there evidence, knowing convincing the support, by clear also the amount falsity standard. It contends was erroneous- award was and that certain evidence excessive have we vacated ly permitted to be introduced. Since award, necessary it not reach punitive damages evidentiary At new trial excessiveness or issues. below, nor presented are parties not limited evidence rulings. Middle they by previous evidentiary are limited See Thomas, 699, 703-704, 668 7-8 A.2d States (1995); Zenobia, Owens-Illinois v. supra, 469-473, 325 Md. at 657-659, 601 A.2d at and cases there cited. As to sufficiency, it must be remembered that and the trial court guided were somewhat overly broad “reckless disre gard” standard for punitive damages set forth in our earlier defamation cases. Once the evidence is introduced at the new trial, the trial court must determine if there is sufficient *10 evidence, under the principles set forth in this opinion, present the punitive issue of damages to jury. the If the trial court determines that submission of the issue to the jury is warranted, it must-instruct jury the that punitive damages may be awarded to plaintiff there is clear and convincing evidence that the defendant had actual knowledge that defamatory statement it made was false.

JUDGMENT FOR PUNITIVE DAMAGES THE OF CIR- CUIT COURT FOR MONTGOMERY COUNTY RE- VERSED, AND CASE REMANDED TO THAT COURT A FOR TRIAL NEW ON PUNITIVE DAMAGES. COSTS BE TO PAID BY THE PLAINTIFF-APPELLEE.

BELL, C.J., dissents.

BELL, Judge, Chief dissenting.

The majority opinion today continues the inexorable cam paign that 1992, this Court began in in Owens-Illinois v. Zenobia, 420, 325 Md. 601 (1992), A.2d 633 to eliminate punitive damages and thereby insulate reprehensible, certain conduct from proper punishment. intent, Its the majority will protest, is not the elimination punitive of damages, but the assurance that damages such are awarded they when serve a function; however, real the elimination punitive damages is the effect when the standard for the punitive allowance of damages is raised to a level virtually impossible to By meet.1 requiring, in addition to clear and convincing proof, on, about, My 1. views raising and concern respect the bar with proof of punitive' damages entitlement length were set forth at Owens-Illinois, Zenobia, 633, Inc. v. 325 Md. 601 A.2d 662 J., (1992)(Bell, concurring dissenting). I continue to believe the

657 were actions the defendant’s prove 652, 709 A.2d 349 Md. wrongdoing,” of “conscious product ” “ id. at wrongdoing,’ deliberate (1998) ‘knowing and 1226 Savings, 337 v. Ellerin (quoting 1226 652, at 709 A.2d Fairfax (1995)), 1117, this Court has 1123 216, 229, 652 A.2d Md. has been which damages, proof the bar raised the bar raising Zenobia. practice And that since the drill eliminating punitive virtually the effect has had Zenobia, has reversed fact, this Court In since Maryland. reversal or affirmed damages, awarding punitive judgment court, nearly appellate intermediate by the awards of such v. See Scott was raised. the issue in which every case Asner, v. ACandS (1997); Jenkins, 21, 1000 690 A.2d Md. 345 Garrett, (1996); Owens-Coming v. 155, 250 686 A.2d 344 Md. Thomas, v. (1996); Middle States 1143 682 A.2d Md. 343 Godwin, 340 Md. v. ACandS (1995); A.2d 5 Md. 668 340 Wilson, v. 339 (1995); Montgomery Ward 116 667 A.2d Savings, (1995); Ellerin v. 664 A.2d Md. Fairfax Evander, Md. (1995); Alexander v. 652 A.2d Md. Baltimore, v. Gypsum U.S. (1994); Sparks, *11 331 Md. Komomik (1994); 145, 647 405 A.2d Coates, 1, 626 A.2d 36 v. Md. Adams (1993); 331 629 A.2d 721 (1993); Bowden, 632, 959 625 A.2d v. (1993); 330 Md. Caldor (1992); Balbos, 179, 445 604 A.2d v. 326 Md. Eagle-Picher 107, 107, 604 A.2d 326 Md. Armstrong, v. 326 Owens-Illinois Associates, 334 Logan v. Robert (1992). Only Macklin 47 (1994) 112, we allow 287, 312, 124 did 639 A.2d Md. solely we stand, that was because but damages award tenant, case, the was in that defendant determined damages a punitive review of discretionary not entitled had not been the issue it because against entered judgment for review. preserved reprehensi- of the allowance protest again

I once write way puni- by punishment from being insulated conduct ble decisions, Indeed, events and correct. expressed therein are views years, buttressed today, last six have over the including the one belief. 658 case,

tive damages. In this the majority has changed the standard for award of punitive defamation cases. today, Before this Court had held that the proof required the award of punitive damages that the defam- atory statement was false or that it was made with reckless Franchino, truth. See Marchesi v. disregard for the 283 Md. 131, 139, (1978); 387 A.2d General Motors Corp. v. 1133 Piskor, 165, 174, 352 A.2d Jacron (1976); Sales Co. v. Sindorf, 580, 601, Md.

(1976). Although consistent with pronouncements of the Supreme subject Court on the see New York standard, of the Sullivan, Times Co. 254, 286, U.S. 84 S.Ct. Welch, (1964); Inc., Gertz v.

L.Ed.2d 686 Robert 418 U.S. 94 S.Ct. (1974), 41 L.Ed.2d 789 this Court went even further applying that standard to all cases. Today, citing Zenobia progeny, and, its in particular, Ellerin, the majority overrules these cases and replaces the standard they announced with one requiring that the plaintiff establish the defendant’s actual knowledge of of the defamatory statement.

The majority reasons from Ellerin’s analysis of the distinc- tion between “reckless indifference” and “actual knowledge.” analysis That indifference,” concluded that “reckless although one of the elements of fraud or deceit and although sufficient to support an award for compensatory damages, was not in fact, the equivalent of “actual knowledge.” While acknowl- edging that acting with “reckless indifference” indicates that the defendant has “actual knowledge” of his or her lack of knowledge as to the veracity or falsity statement, majority asserts that is not enough; what must be shown is knew, fact, the defendant that the statement was false. Applying that rationale to the requirement in defamation cases that the statement be made disregard” “reckless *12 truth, the majority reaches the identical result in this Ellerin, defamation case as it reached in a deceit case. Ellerin, I in dissented taking issue with the change law and noting the conduct reflected proceeding that with than the reprehensible was no less “reckless indifference” knowledge: actual engaged conduct with thus, and, Maryland well long has been the law “It defendant, to mislead the settled, intending that a he or she does not know whether the fully aware that false, is true or commits the representation he or she makes Parks, E.g., tort of or deceit. Robertson fraud (1892). underlying 24 A. The rationale fact, of a with making representation the rule is that a knowledge speaker and actual that intent deceive not, not know it is fact or is as much a does whether knowledge one made actual misrepresentation as - as knowledge repre and that actual of the former is Fully recogniz- hensible as actual of the latter. law, ‘Maryland ... that cases ing noting the state but concerning typically fraud or deceit have involved the form deliber- the tort which is characterized the defendant’s deception plaintiff by representation ate of the means false,’ he majority which knows to be nevertheless tort, to knowledge prong ‘refines’ the actual of the include so, that, fully cognizant situation.... And it does understood, traditionally as the tort countenanced no negligence, amount of however is gross.... There abso- lutely majority’s change no basis for the of the law.” (citations omitted). 337 Md. at 652 A.2d at 1131 Because Ellerin, on majority’s just reliance those comments are applicable as to this case.

An additional damage observation is order. The defamed person actually is the same whether the defamer knows that saying simply what he she is is false or knows he she does not know the statement is true or false. more and distressing today, What is most to me is after it simply will not be important to ensure that what is communi cated about I person interpret majori another true. As ty opinion, long as as there is no evidence that the defamer and, actually knew the information I suppose, was false did obvious, not shut his or her eyes what must have been it does not matter that a brief investigation would have made *13 statement; may falsity publish clear the defamer impunity, any false statement about the without records, and, beyond yet, his or her own remain investigation damages.2 you from the risk of And can bet insulated happen that is what will today’s opinion precisely that after frequency. more with more and dissent, I respectfully. most

709 A.2d 1230 PHILIP et al. MORRIS INCORPORATED

Parris N. et al. GLENDENING 10, Sept. Term,

No. 1997. Maryland. Appeals Court May 1998. instructed, jury

2. The after all: exists, one, malong deliberately person "Malice when a statement lies or makes the statement with it is false or with or, two, person disregard when the reckless as to the truth or making the had an obvious reason to distrust either the statement accuracy person of the statement or the source from which the or, three, finally item when the statement learned of the statement person making inherently improbable that invented it or is so write, person say, print it.” a reckless would

Case Details

Case Name: Le Marc's Management Corp. v. Valentin
Court Name: Court of Appeals of Maryland
Date Published: May 19, 1998
Citation: 709 A.2d 1222
Docket Number: 129, Sept. Term, 1996
Court Abbreviation: Md.
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