Cases & Developments

Opinion Granting in Part Defendants’ Motion to Dismiss. Plaintiff, a former student-athlete and member of the men’s basketball team at Pennsylvania State University, brought defamation claims against the university and its head basketball coach based on a series of statements allegedly made by the coach concerning plaintiff’s departure from the team. The court held that plaintiff had sufficiently stated a defamation claim against the coach based on the coach’s statements that (1) plaintiff had refused to return to the university because his father was “after more money”; and (2) plaintiff “decided himself” that he was going to leave the university. In both instances, the court found it “reasonable to infer . . . that [the coach’s] statements caused financial harm to [plaintiff] by harming his reputation and forcing him to attend a less prestigious university.” However, the court dismissed plaintiff’s claims regarding other statements made by the coach, finding the allegations lacked necessary details as to the content, audience, and timing of the statements. The court also dismissed plaintiff’s defamation claims against the university, finding no basis to impose vicarious liability since plaintiff had failed to show the coach’s statements were made within the scope of his employment or with the purpose of serving the university.