Bradbury v. Teacher Standards & Practices Commission

*185WARREN, P. J.,

dissenting.

Because plaintiffs claim is for damage to his reputation caused by defendant’s negligently permitting the release of information, it is one for defamation and is subject to a one-year statute of limitation. ORS 12.120(2). It is of no significance that defendant’s negligent supervision of its former employee may have permitted the defamation. The cause of the damage is the publication of defamatory material.

Contrary to the majority’s belief, Coe v. Statesman-Journal Co., 277 Or 117, 560 P2d 254 (1977), and Magenis v. Fisher Broadcasting, Inc., 103 Or App 555, 798 P2d 1106 (1990), do control this case and I would therefore affirm. In Coe, the defendant mistakenly identified the plaintiff in the newspaper as a convicted embezzler. The Supreme Court held that the one-year statute of limitations governed the plaintiffs defamation action. Noting that “ ‘defamation protects the interest in reputation,’ ” the court stated that the plaintiffs action was “an action for defamation, regardless of whether the publication was intentionally, negligently, or inadvertently made.” Coe, 277 Or at 120 (quoting 1 Harper and James, The Law of Torts 349, § 5.1). Thus, it was not the quality of defendant’s culpability in the publication but the nature of the harm alleged that dictated the proper statute of limitation.

In Magenis, the defendant televised film clips purporting to link the plaintiffs to criminal activity. We concluded that the one-year statute of hmitations applied to the plaintiffs’ false-light claim. We stated that, when a claim characterized as false light alleges facts that also constitute a claim for defamation, the statute of limitations for defamation controls. Magenis, 103 Or App at 560. Again, the nature of the harm alleged to have resulted from the publication dictated the proper statute of limitations.

In this case, plaintiff has alleged that, as a result of defendant’s negligence, one of defendant’s former employees published false information that plaintiff had sexually assaulted a student and that he was “subjected to loss of public esteem, respect, goodwill and confidence and has been disgraced and degraded.” 151 Or App 179. The gist of plaintiffs cause of action is that his reputation was damaged as a result *186of defendant’s direct or indirect communication of false information to a third person. His claim is therefore one for defamation. It makes no difference how the claim is characterized; when a claim, however styled, otherwise “alleges facts that also constitute a claim for defamation, the claim must be filed within the period for bringing a defamation claim.” Magenis, 103 Or App at 560. It makes no difference whether the publication results from defendant’s own intentional, negligent or inadvertent conduct or the conduct of another for whose action defendant is liable.1

The trial court correctly concluded plaintiffs claim was for defamation and was subject to a one-year statute of limitation.

I dissent.

The majority inadequately explains how TSPC can be liable for publication of information by a former employee acting outside the employment relationship or how, after the employment relationship had ended when the disclosure was made, TSPC had a duty or right to supervise him. While plaintiff did allege that the investigator was inexperienced and not instructed on the duty to maintain confidentiality, there is no allegation that TSPC knew or should have known that he was unaware of or would violate the confidentiality statute. See Mathews v. Federated Service Ins. Co., 122 Or App 124,135, 857 P2d 852, rev den 318 Or 25 (1993).

Likewise, the majority fails to explain how any damage can result from a failure to supervise per se. The only damage alleged is that which resulted from the publication.