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Kerns v. Ishida

Citation: 2022 NY Slip Op 05276Docket: Index No. 161364/20 Appeal No. 16274 Case No. 2022-02232

Court: Appellate Division of the Supreme Court of the State of New York; September 27, 2022; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this defamation case, the plaintiff, a medical professional, initiated a lawsuit against the defendants following disparaging online reviews about her medical spa. The reviews contained statements such as calling the plaintiff 'a psychotic nutcase' and labeling the spa as 'extremely unprofessional.' The defendants filed a motion to dismiss, asserting that their statements were non-actionable opinions. The Supreme Court, New York County, concurred with the defendants, determining that the language used in the reviews was hyperbolic and opinion-based, thus not meeting the legal threshold for defamation. The court also noted that the content of the reviews, in context, expressed dissatisfaction rather than factual assertions. Despite the defendants' request for costs and attorneys' fees under New York's anti-SLAPP statute, the court refrained from addressing this issue due to the absence of a cross-appeal notice. The Appellate Division affirmed the dismissal of the case, upholding the lower court's finding that the plaintiff failed to substantiate a defamation claim. This outcome left the defendants unburdened by both the defamation claims and the financial repercussions of the lawsuit.

Legal Issues Addressed

Anti-SLAPP Law and Costs

Application: The court did not address the defendants' request for costs and attorneys' fees due to procedural shortcomings regarding a cross appeal.

Reasoning: The court did not address the defendants' request for costs and attorneys' fees under New York's anti-SLAPP law, as the defendants failed to file a notice of cross appeal regarding this request.

Defamation and Opinion

Application: The court decided that the statements made by the defendants were expressions of opinion and thus not actionable as defamation.

Reasoning: The Supreme Court, New York County, granted the defendants' motion to dismiss on November 3, 2021, ruling that the statements were opinion-based, prefaced by expressions of personal opinion, and characterized by hyperbolic language.