United States Second Circuit

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Martin v. Hearst Corporation, 13-3315

In this action brought by plaintiff alleging libel and other publication-related claims against media outlets that published accounts of her 2010 arrest, plaintiff argues that although the accounts were factually true when published, they became false and defamatory when the charges against her were nolled. Under Connecticut's Criminal Records Erasure Statute, when charges against an individual are nolled, that individual's criminal records are erased and he is "deemed to have never been arrested." Summary judgment in favor of defendants and dismissal of each of plaintiff's claims is affirmed, where the Erasure Statute does not render tortious historically accurate news accounts of an arrest.

Appellate Information

  • Decided 01/28/2015
  • Published 01/28/2015


  • Wesley


  • United States Second Circuit


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