Defamation; Thomas M Cooley Law Sch. v. Doe 1; Sarkar v. Doe; Ireland v. Edwards; Ghanam v. Does; Tortious interference; CMI Int’l, Inc. v. Intermet Int’l Corp.; Badiee v. Brighton Area Sch.; Intentional infliction of emotional distress (IIED); Dalley v. Dykema Gossett; Denial of leave to amend the complaint; Futility; PT Today, Inc. v. Commissioner of the Office of Fin. & Ins. Servs.

Concluding that plaintiff failed to sufficiently identify any defamatory statements by defendant-television station, the court affirmed summary disposition for defendant on his defamation claim. It also held that he failed to allege defendant committed an inherently wrongful act, or (with any specificity) affirmative acts that it committed with the motive of interfering with his business or contractual relationships. Finally, he did not describe any extreme or outrageous conduct on defendant’s part. Thus, the court also affirmed summary disposition for defendant on his tortious interference and IIED claims. It found that he did not specifically identify in his handwritten complaint any allegedly defamatory statement by defendant. While he asserted it used the word “scam” in an article (the Red Flags Article), the only time the word appeared in the complaint it was used by plaintiff in stating that his business was not a scam. Although he also “referred to a story in which he claimed that defendant made allegedly defamatory statements,” he did not identify the exact language that was allegedly defamatory and his reference to the story by itself was insufficient. As to tortious interference, he simply alleged that defendant did a story that “damaged his business. Defendant’s act of publishing a story, even if the story contained a lie, was not so inherently wrongful that it could never be justified.” Thus, he had to allege “specific and affirmative acts that defendant intentionally committed in order to interfere with plaintiff’s contractual or business relations.” He did not do so. The court also concluded that at “most, defendant’s conduct, as alleged in the complaint, was insulting and oppressive and did not give rise to an” IIED claim. Finally, it held that the trial court did not err in not allowing him to amend his complaint. Because “defendant outlined the factual basis for its statements in the Red Flags Article, the statements were not actionable under the First Amendment.” Further, given that his other two claims were based “on the same underlying facts and statements as” the defamation claim, the trial court did not abuse its discretion in “dismissing all plaintiff’s claims with prejudice and without leave to amend.”