## Facts

- Carl A. Veno was managing editor and Carl T. Davies was a reporter at *The Free Press*, owned by Charles M. Meredith III.
- On December 28, 1979, the newspaper published a front-page article by Davies, overseen by Veno, questioning a county judge’s business dealings and potential conflicts under the Pennsylvania Code of Judicial Conduct.
- Meredith believed the reporting was unfair and insufficiently researched and ordered Veno to terminate Davies.
- Veno refused to fire Davies; Meredith discharged both Veno and Davies that day.
- On December 31, 1979, the newspaper published a signed editorial by Meredith under “Our Opinion” apologizing to the judge and criticizing the prior reporting as unfair and not thoroughly researched.
- Veno and Davies sued Meredith and the newspaper asserting defamation based on the editorial and employment-related claims; the trial court dismissed the defamation counts on demurrer.
- On the employment claims, the trial court entered a compulsory nonsuit against Veno; Davies’s claim went to the jury and resulted in a verdict for Davies.

## Issues

1. Whether the editorial criticizing the prior article was capable of a defamatory meaning as to Veno and Davies.
2. Whether Veno showed an employment relationship other than at-will employment that limited the employer’s right to discharge him.
3. Whether Veno’s discharge fit within a recognized public-policy exception to Pennsylvania’s at-will doctrine.

## Decision

- The Superior Court affirmed the dismissal of the defamation claims, holding the editorial was not capable of defamatory meaning as a matter of law.
- The court treated the editorial’s characterization of the reporting as “unfair” and “not thoroughly researched” as nonactionable opinion based on disclosed facts (the article itself), not a provably false factual accusation about the plaintiffs.
- The court affirmed judgment for defendants on Veno’s employment claim, concluding Veno was an at-will employee.
- The court held Veno produced insufficient evidence of an express or implied contract (including any “additional consideration”) altering at-will status.
- The court declined to extend Pennsylvania’s narrow public-policy exception to cover Veno’s discharge for refusing to fire Davies over an editorial dispute.

## Legal Principles

- Whether a communication is capable of defamatory meaning is a question of law for the court.
- Statements framed as opinion, especially when based on disclosed facts available to readers, generally are not actionable because they do not imply undisclosed defamatory facts.
- Criticism of a published work product (e.g., fairness or thoroughness of an article), without asserting concrete false facts about the author, may be insufficient to meet the defamatory-meaning threshold.
- In Pennsylvania, employment is presumed at will absent a contract for a definite term or other recognized limitation; at-will employees may be terminated for any reason or no reason.
- Public-policy exceptions to at-will employment are narrow and typically require discharge that contravenes a clear mandate of public policy (such as requiring illegal conduct or defeating a statutory duty).

## Conclusion

The court held that a newspaper owner’s signed editorial, labeled as opinion and grounded in the previously published article, was not actionable defamation, and it reaffirmed that a managing editor without contractual job protection is an at-will employee whose discharge over an internal editorial dispute does not, without more, create a wrongful discharge claim under Pennsylvania public policy.


Veno v. Meredith, 357 Pa. Super. 85, 515 A.2d 571 (1986)