Anonymity of Libel Helps Justify Punitive Damages
From Riccio v. Morelli, decided Friday by the Maryland Court of Special Appeals, in an opinion by Judge Zarnoch, joined by Judges Friedman and Gould:
In her decision, the Arbitrator, retired Court of Appeals Judge Irma S. Raker, laid out the background of the case:
Robert Riccio and Richard Morelli were friends for many years. This dispute arises from the [Riccio] Foundation golf tournament in June 2016, held in Ocean City, Maryland. The registration fee for the tournament was $450.00. Many of the participants, including Riccio and Morelli, stayed at the Tidelands Hotel in Ocean City. On the evening of June 4, 2016, Morelli and several of the other tournament participants ate dinner at the Embers Restaurant where the tournament sponsored an all-you-can-eat buffet dinner. A dispute arose between Morelli and the management regarding an unpaid bar bill ($25.00) and some missing cash left on the table. The Ocean City Police Department was called by the restaurant. The incident was resolved with no arrests and Morelli and his friend returned to the hotel by city bus.
The next morning, Riccio called Morelli in a heated telephone call. Morelli stated that before Riccio hung up, he said: “you’re going to find out how many ways I can hurt you, now pack your bags.” Riccio wanted Morelli to return to the Embers Restaurant to clear the air, to resolve any unresolved issues with the restaurant, and to generally protect the reputation of the golf event. Morelli refused. Ultimately, Riccio, who leased all the hotel rooms, asked the hotel to “evict” or remove Morelli, and according to Riccio, the hotel management told Morelli to leave. Morelli also issued a stop payment order on his golf tournament registration of $450 (and later sent a check for $94.99, which Riccio never cashed).
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