Defamation; Whether defendants’ challenged statements were capable of defamatory meaning & thus actionable; Ireland v. Edwards; Smith v. Anonymous Joint Enter.; False light invasion of privacy; Derderian v. Genesys Health Care Sys.; Rouch v. Enquirer & News of Battle Creek (After Remand); Challenges to statements made by defendants-Jatczak, Clohessy, & Survivors Network of Those Abused by Priests (SNAP); Milkovich v. Lorain Journal Co.; Philadelphia Newspapers v. Hepps; Ghanam v. Does; Kevorkian v. American Med. Ass’n

Holding that the statements in defendants’ publications were either substantially true or nonactionable opinions, the court affirmed. Plaintiff became an ordained priest in 1976. In 2009, “the Archdiocese of Detroit issued a press release announcing that allegations of sexual misconduct, dating back to the early years of his ministry, were made against plaintiff by a former parishioner at his former parish . . . .” One of the defendants-reporters wrote an article for defendant-Macomb Daily concerning plaintiff. He quoted defendant-Jatczak, of the Michigan chapter of defendant-SNAP. Defendant-Clohessy, the Executive Director of SNAP, issued a press release about plaintiff. Defendant-Free Press also published articles about plaintiff. Plaintiff argued that the trial court erred in deciding that defendants’ communications about him were not actionable. To “establish either a claim for defamation or a claim for false light invasion of privacy, the plaintiff must show that what the defendant stated was false.” Thus, the court began by addressing whether the statements and information in the articles were false. The Rouch court held that a “minor inaccuracy about which individuals identified him, as well as the technically incorrect use of legal terminology with respect to the word ‘charged,’ did not impact the substantial truth of the article.” The court concluded that the trial court did not err by ruling that there was no genuine issue of material fact as to whether the statements in the Macomb Daily and the Detroit Free Press publications “were materially false.” As to the other defendants, because the challenged statements were “not defamatory as a matter of law, the trial court did not err” in granting them summary disposition.