Roger Byrge v. Stacey Campfield, et al.

This is a defamation case. Based on information that he received from a political source, then State Representative Stacey Campfield (“Campfield”) posted remarks on his blog alleging that candidate for State House Roger Byrge (“Byrge”) had been arrested on drugrelated charges. The information, however, turned out to be false. Byrge lost the election and sued Campfield for defamation in the Circuit Court for Campbell County (“the Trial Court”). Campfield, asserting that at the time of the posting he had no reason to doubt the accuracy of the information, moved for summary judgment. The Trial Court granted Campfield’s motion. Byrge appealed. We hold that the record before us in this case concerning the alleged defamation of a public figure contains evidence that is clear and convincing from which a trier of fact could find actual malice in Campfield’s publication of false statements about Byrge. We reverse the Trial Court and remand this case for further proceedings on Byrge’s claims against Campfield for defamation and false light invasion of privacy.