Illinois Appellate Court
Civil Court
Defamation
Plaintiff filed action against Defendants, members of a Church, alleging they had committed defamation per quod, false light invasion of privacy, and intentional infliction of emotional distress against him when they signed a memorandum entitled “Reprimand of Deacon Moon” and published it to multiple third parties within and outside of the church. Court properly dismissed complaint with prejudice, pursuant to Section 2-615. Court properly found that Plaintiff could not satisfy element of false light requiring that false light would be highly offensive to a reasonable person. There is no special standard that applies to ethnic minorities with devout religious practices. No causal connection between statement and Plaintiff’s purported special damages. No factual allegations to show that Defendants’ conduct was extreme and outrageous, or that they knew of high probability their conduct would inflict severe emotional distress. (HOWSE and COBBS, concurring.)