## Facts

- Barbara Rose Collins, a sitting U.S. Representative running for reelection, gave a recorded interview in May 1996 to a reporter for a news service; the recording and transcript were provided to a Michigan newspaper.
- On July 17, 1996, the newspaper published an article on Collins’s views on racism and quoted her as saying: “I love the individuals, but I hate the race,” referring to “the white race.”
- Collins publicly disputed the quotation and explained she meant she hated historical wrongs committed by whites against people of color.
- A follow-up wire story repeated the quotation and reported it had been verified as accurate.
- After Collins lost the August 1996 primary, the newspaper published a retraction stating she had been quoted incorrectly and acknowledging error.
- Review of the recording showed Collins actually said: “I love the individuals, but I don’t like the race.”
- Collins sued for defamation and related tort and statutory claims; defendants moved for summary disposition on the ground that any inaccuracy was not materially false.
- The trial court denied summary disposition on defamation, reasoning “hate” carried a substantially different impact than “don’t like” in the local setting; defendants obtained interlocutory review.

## Issues

1. Whether, in a public-official/public-figure defamation claim, substituting “hate” for “don’t like” in a quoted statement materially changed the meaning such that the statement was actionable.
2. Whether the material-falsity/substantial-truth inquiry is assessed objectively by the “gist” or “sting” of the publication, rather than by localized reactions.

## Decision

- The appellate court reversed the order denying summary disposition on the defamation claim and remanded.
- The court held the “hate” versus “don’t like” substitution did not constitute a material falsification as a matter of law.
- Because the challenged statement was substantially true in its gist, defendants were entitled to summary disposition on defamation notwithstanding the retraction.

## Legal Principles

- A public official/public figure must prove material falsity; minor inaccuracies are not actionable if the publication’s “gist” or “sting” is substantially true.
- Misquotations, even if inaccurate, are not materially false unless the alteration creates a material change in the meaning conveyed to readers.
- Material falsity may be decided as a question of law where the underlying words and context are not genuinely disputed and the effect can be evaluated objectively.
- The substantial-truth/material-falsity analysis does not turn on whether some readers might react more strongly to a particular word choice; it turns on whether the alteration changes the substance of the alleged defamatory charge.

## Conclusion

The court held that, in context, quoting a public official as saying she “hate[d]” a race instead of saying she “d[id]n’t like” a race did not materially change the gist of the publication, so the statement was substantially true and could not support a defamation claim.


Collins v. Detroit Free Press, Inc., 627 N.W.2d 5 (Mich. Ct. App. 2001)