Defamation; Hope-Jackson v Washington; Truth as an absolute defense; TM v MZ; Public disclosure of private facts; Doe v Henry Ford Health Sys; False-light invasion of privacy; Puetz v Spectrum Health Hosps; “Malice” & reckless disregard; Intentional infliction of emotional distress (IIED); Hayley v Allstate Ins Co; “Mere insults, indignities, threats, annoyances, petty oppressions, or other trivialities”; Doe v Mills; “Extreme & outrageous” conduct; Civil conspiracy; Swain v Morse; Underlying tortious conduct requirement; Alleged violations of MCL 28.214, 752.794, 752.795, & 752.796; Private cause of action to enforce a statutory right; Lane v KinderCare Learning Ctrs

The court held in these consolidated appeals that the trial court did not err by granting defendants-Charles and Cynthia Reilly summary disposition of plaintiff’s claims. She sued Charles for defamation, public disclosure of private facts, false-light invasion of privacy, and IIED, and sued both Charles and Cynthia for civil conspiracy. Her claims arose out of a Facebook post that plaintiff alleged implied she was convicted of a felony. She had previously pled guilty to a misdemeanor, which was later set aside. The trial court granted summary disposition for defendants. On appeal, the court first found that as to plaintiff’s defamation claim, “Charles’s statements concerning plaintiff’s criminal charges and the length of imprisonment she faced if convicted are true.” And his reference to plaintiff as a criminal “is also true because plaintiff acknowledges she was convicted of a misdemeanor. While plaintiff notes her conviction was set aside and Charles does not dispute this assertion, the fact that the misdemeanor conviction was set aside does not change the fact that plaintiff was convicted of a crime.” Next, as to plaintiff’s public disclosure of private facts claim, the court found the undisputed evidence established that Charles “referenced ‘matters that [were] already of public record or otherwise open to the public.’” Further, as to plaintiff’s false-light invasion of privacy claim, it found “the undisputed evidence does not support that plaintiff was placed in a false light.” And as to her IIED claim, “the trial court properly concluded that Charles’s statements essentially amount to ‘mere insults, indignities, . . . annoyances, petty oppressions, or other trivialities,’ and such statements are not actionable.” Finally, plaintiff could not “rely on MCL 28.214, MCL 752.794, MCL 752.795, and MCL 752.796 to support her civil conspiracy claim because [she] does not have private causes of action under those statutes.” Affirmed.