## Facts

- Rhonda Walker Tallent worked for a county school system’s food service office performing secretarial and bookkeeping tasks and assisted with limited payroll check preparation under the direction of the board’s computer operator.
- After the computer operator resigned, Tallent was asked to run payroll for all ten-month employees; Tallent said she did not know how.
- Tallent met with Superintendent Jerry Lee Blake and left believing she had been fired; Blake later testified Tallent quit and he treated it as a resignation.
- A newspaper reporter called Blake, who stated that two people had resigned and that “Any claim Mrs. Tallent was fired is false,” which was published.
- Tallent sued Blake (individually) for slander, seeking actual and punitive damages, based on the statement to the reporter.
- Tallent offered evidence of financial difficulties after losing her job (missed payments and a later Chapter 13 filing) and emotional distress requiring medical attention.

## Issues

1. Whether the statement “Any claim Mrs. Tallent was fired is false” constituted slander per se under North Carolina law.
2. If not slander per se, whether Tallent alleged and proved legally sufficient special damages proximately caused by the publication.
3. Whether the trial court erred by denying Blake’s motions for directed verdict and judgment notwithstanding the verdict (JNOV) on the actual-damages slander claim.

## Decision

- The Court of Appeals reversed the judgment for Tallent and remanded with instructions to enter judgment for Blake.
- The statement was not slander per se because it did not accuse Tallent of a crime, impute a loathsome disease, or impeach her in her trade or profession.
- Because the statement was not actionable per se, Tallent was required to plead and prove special damages.
- Tallent’s evidence did not establish specific pecuniary loss caused by the publication, as opposed to harms attributable to the loss of employment.
- The trial court should have granted Blake’s directed-verdict/JNOV motions.

## Legal Principles

- North Carolina generally limits slander per se to statements that (1) charge a crime involving moral turpitude, (2) impeach the plaintiff in her trade or profession, or (3) impute a loathsome disease.
- A statement outside the per se categories is actionable only upon proof of special damages.
- Special damages in slander are specific, pecuniary losses that are the direct and natural result of the defamatory publication; emotional distress and generalized financial hardship are insufficient without a concrete causal link to the publication.
- When the evidence, viewed in the plaintiff’s favor, fails to establish an essential element (such as per se defamation or special damages), the defendant is entitled to judgment as a matter of law.

## Conclusion

The court held that a superintendent’s public statement disputing that an employee was “fired,” without more, is not slander per se, and the employee’s post-termination financial and emotional problems did not constitute special damages tied to the publication; judgment was therefore required for the defendant.


Tallent v. Blake, 291 S.E.2d 336 (N.C. Ct. App. 1982)