United States Third Circuit

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Graboff v. Colleran Firm, 13-2229

In an action for false light invasion of privacy and defamation brought against defendant, a voluntary professional organization for orthopaedic surgeons, following defendant's printing of an article describing grievance proceedings against plaintiff which resulted in his suspension from defendant's membership, the district court's order denying defendants' motion for judgment as a matter of law and for judgment notwithstanding the verdict is affirmed, where: 1) the jury's answers that that the article did not contain any false statements, but did contain statements portraying plaintiff in a false light can be reconciled and thus were not inconsistent; 2) the district court erred by treating the jury's findings as returning a verdict in plaintiff's favor only on the false-light claim as the findings established that defendant was liable on both the false-light and defamation claims; but 3) the error was harmless.

Appellate Information

  • Decided 02/20/2014
  • Published 02/20/2014




  • United States Third Circuit


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