LORRAINE MARTIN, Individually and on Behalf of all Others Similarly Situated, Plaintiff-Appellant, -v.- HEARST CORPORATION, SOUTHERN CONNECTICUT NEWSPAPERS, INC., dba DAILY GREENWICH, NEWS 12 INTERACTIVE, INC., Defendants-Appellees, MAIN STREET CONNECT, LLC, Defendant., 777 F.3d 546

Summary

HOLDINGS: [1]-Plaintiff repeated her argument that, even though she was arrested, once erasure occurred in January 2011, pursuant to Connecticut's Criminal Records Erasure Statute, Conn. Gen. Stat. § 54-142a, it became false and defamatory to publish statements regarding that arrest; [2]-She misunderstood the effect of the statute; [3]-The statute did not render tortious historically accurate news accounts of an arrest; [4]-Because there was no dispute that the articles published by the media outlets accurately report plaintiff's arrest, her various publication-related tort claims necessarily failed; [5]-Her claims for libel, placing another in a false light, negligent infliction of emotional distress, and defamation by implication failed.