## Facts

- Janell Standifer rented an apartment managed by Val Gene Management Services, Inc. (Val Gene).
- Standifer moved out of the apartment at Val Gene’s request.
- After moving, Standifer learned that a Val Gene agent (Sharon Gayle Wright) had allegedly told several people that Standifer was a “constant troublemaker,” “not a fit tenant,” “harassing,” had “cussed her out,” was “disruptive,” and was bothering other tenants, along with other statements said to degrade her reputation.
- Standifer sued Val Gene for slander, alleging the statements were false and malicious and seeking $5,000 in general damages and $25,000 in punitive damages.
- As actual damages, Standifer claimed moving-related expenses: $375 moving expense, $15 telephone expense, $20 automobile expense, and $80 additional rent.
- In the trial court, Val Gene challenged the sufficiency of Standifer’s claim and, after depositions, moved for summary judgment on the ground that even if the alleged statements were made, they were not actionable as slander per se and Standifer could not show recoverable damages.
- It was undisputed for purposes of the motion that Standifer did not learn of the alleged statements until after she had already moved out.

## Issues

1. Whether the alleged statements (e.g., “constant troublemaker,” “not a fit tenant,” “harassing,” “disruptive,” and similar remarks) constitute slander per se under Oklahoma law.
2. If the statements are not slander per se, whether Standifer alleged and could prove special damages proximately caused by the alleged publication.
3. Whether summary judgment for Val Gene was proper where, even accepting Standifer’s version of the statements, the claim failed as a matter of law.

## Decision

- The Oklahoma Court of Civil Appeals affirmed summary judgment for Val Gene.
- The court held the statements attributed to Val Gene’s agent were not within recognized categories of slander per se.
- Because the statements were not actionable per se, Standifer was required to plead and prove special damages.
- Standifer’s claimed moving-related expenses could not be treated as special damages caused by the alleged slander because she moved before learning of the statements, breaking the causal connection.
- With no actionable slander per se and no legally sufficient showing of special damages caused by the alleged publication, Val Gene was entitled to judgment as a matter of law.

## Legal Principles

- Slander per se is limited to specific categories recognized by Oklahoma law (including statements charging a crime, imputing a loathsome disease, directly injuring a person in a profession or business, or imputing unchastity to a woman).
- Statements that merely characterize a tenant as a “troublemaker,” “not a fit tenant,” “harassing,” “profane,” or “disruptive,” without fitting a recognized category, are not slander per se.
- When alleged defamatory words are not slander per se, the plaintiff must plead and prove special damages—specific pecuniary loss.
- Special damages must be shown to have been proximately caused by publication of the defamatory words; expenses incurred for reasons unrelated to learning of the publication do not satisfy causation.
- Summary judgment is proper in a defamation action when, even assuming the statements were made, the words are not actionable per se and the evidence cannot support a required element such as causation of special damages.

## Conclusion

The court affirmed summary judgment because the tenant-directed remarks did not qualify as slander per se, and the plaintiff’s claimed moving expenses could not be linked to the publication where she moved before learning of the statements, leaving no recoverable damages as a matter of law.


Standifer v. Val Gene Management Services, Inc., 527 P.2d 28 (1974)