Joseph E. Hancock v. Easwaran P. Variyam
Joseph E. Hancock appealed a defamation judgment in favor of Easwaran P. Variyam. The case stemmed from a letter Hancock wrote to Variyam's superiors and a professional accreditation body, alleging Variyam had a "reputation for lack of veracity" and "deals in half truths." The trial court found these statements to be libel per se, and a jury awarded Variyam $90,000 in actual damages and $85,000 in exemplary damages. Hancock challenged the libel per se finding, the sufficiency of damages evidence, and the admission of an anonymous letter at trial. The Court of Appeals for the Seventh District of Texas affirmed the trial court's judgment, upholding the libel per se finding and the damage awards, and deeming any error regarding the anonymous letter harmless.