Indiana Court of Appeals
Eve Carson v. Stacy Palombo
Civil plenary. Affirms trial court grant of summary judgment in favor of Palombo on Carson’s claims of defamation per se, defamation per quod and invasion of privacy by false light based upon Palombo’s comments regarding a YouTube video Carson posted criticizing the investigation of her sister-in-law’s decades-old murder. The trial court did not abuse its discretion in denying Carson’s motion to amend her complaint to include facts she knew but omitted at the time her original complaint was filed to defeat a grant of summary judgment in Palombo’s favor. There is no genuine issue of material fact that Carson’s claimed damages were incurred as a consequence of alleged defamatory statements, and in the light of other videos Carson posted on YouTube, she was cast in essentially the same light as Palombo’s comment.