Catherine Swerdlick v. Robert P. Koch

Summary

The Supreme Court of Rhode Island affirmed judgment as a matter of law for Koch on the Swerdlicks' privacy, defamation, false-light, and emotional-distress claims. The court held that photographing and reporting publicly visible activity did not invade a protected private area or disclose private facts, that the challenged statements were substantially true or unsupported by proof of damages, and that Koch's conduct was neither sufficiently outrageous nor causally actionable. The court also declined to recognize the proposed alternative emotional-distress theory under the circumstances presented.