Bartlett v. Bradford Publishing

1 In this case, we consider whether Appellant, Heil Bartlett, a public figure, can satisfy the actual malice standard in a defamation suit by alleging that Appellees, Bradford Publishing, Inc. d/b/a The Bradford Era, John Satterwhite, Marty Wilder and Anne Holliday (collectively "The Bradford Era"), engaged in sub-standard reporting and investigative practices. The trial court found that Bartlett failed to produce evidence that The Bradford Era acted with actual malice and entered summary judgment in its favor. On appeal, Bartlett contends that the trial court erred because it failed to view the evidence in a light most favorable to him as the non-moving party and failed to consider evidence proving that The Bradford Era published the articles with only limited inquiry into the veracity of its story and sources. We hold that although The Bradford Era may have engaged in substandard journalistic practices, substandard journalistic practices do not satisfy the actual malice standard. We conclude, accordingly, that the trial court did not abuse its discretion or commit an error of law when it entered summary judgment in favor of The Bradford Era. Consequently, we affirm the Order of the trial court granting summary judgment.