Covino v. Hagemann
The plaintiff, Lee Covino, sued defendant Ray E. Hagemann for defamation (libel and slander) after Hagemann sent a note to Covino, copied to Borough President Guy Molinari, accusing Covino of 'racially insensitive attitudes' towards Ed Watkins. Hagemann also allegedly repeated these statements to newspaper employees. The court considered whether the statements were actionable facts or protected opinions. Applying the three-prong test from Gross v New York Times Co., the court found terms like 'racially insensitive' to be vague, ambiguous opinions incapable of being proven true or false, and not implying undisclosed defamatory facts. The court also rejected claims that the statements constituted a crime or harmed Covino in his profession, stating they were nonactionable rhetorical hyperbole. Consequently, the motion to dismiss the complaint for failure to state a cause of action was granted, and the complaint was dismissed, with attorneys' fees denied.