## Facts

- Joseph L. Chapadeau, a public school teacher, was arrested in Utica, New York, and charged with criminal possession of a hypodermic instrument and fourth-degree criminal possession of a dangerous drug (heroin).
- The next day, a newspaper article reported Chapadeau’s arrest along with two other drug-related arrests.
- The article included statements asserting the three men were part of a group at a party in Brookwood Park where they were arrested and where drugs and beer were found.
- Chapadeau alleged these statements were false and defamatory because they linked him to the park party and the claimed discovery of drugs and beer.
- The newspaper conceded the statements were inaccurate but argued its reporting was privileged and sought summary judgment.

## Issues

1. What fault standard governs a defamation claim by a private individual when the publication concerns a matter arguably within the sphere of legitimate public concern?
2. Under that standard, did the record permit a jury to find the newspaper liable, or was summary judgment for the newspaper proper?

## Decision

- The New York Court of Appeals affirmed summary judgment for the newspaper and dismissed the defamation claim.
- The court held the arrest of a public school teacher on drug-related charges was arguably within the sphere of legitimate public concern and the article was reasonably related to that concern.
- The court adopted a “gross irresponsibility” standard for private-figure defamation claims involving matters of legitimate public concern.
- On the undisputed record, the newspaper’s reliance on police sources and internal review procedures did not amount to gross irresponsibility; failure to discover and correct the error was insufficient to require a trial.

## Legal Principles

- For publications arguably within the sphere of legitimate public concern and reasonably related to that concern, a private plaintiff must prove the publisher acted “in a grossly irresponsible manner without due consideration for the standards of information gathering and dissemination ordinarily followed by responsible parties.”
- The standard is a state-law fault requirement consistent with constitutional limits: liability may not be imposed without fault for defamation of private individuals.
- Routine reliance on official sources (such as police personnel and records), combined with internal checking, may defeat a claim that the publisher acted in a grossly irresponsible manner, even if the report contains a defamatory inaccuracy.

## Conclusion

New York required a private plaintiff challenging a defamatory falsehood in reporting on matters of legitimate public concern to prove the publisher acted in a grossly irresponsible manner, and it upheld summary judgment because the newspaper’s newsgathering and review did not meet that level of fault.


Chapadeau v. Utica Observer-Dispatch, Inc., 38 N.Y.2d 196, 341 N.E.2d 569 (N.Y. 1975)