Plaintiff, a private investigator who worked with Northwestern Law School's Innocence Project, sued various defendants for defamation, false light invasion of privacy, intentional infliction of emotional distress, and civil conspiracy. Trial court erred in granting motion of Defendant attorney Ekl (who represented a man whose conviction was vacated after Ekl filed successive postconviction petition asserting actual innocence) to dismiss claims of defamation and false light publicity as time-barred. Because screenings of documentary "Murder in the Park" each constituted a separate publication of the allegedly defamatory material, the single-publication rule does not apply. Even though film had premiered in New York City more than 1 year prior to filing of Plaintiff's complaint, Plaintiff timely filed his complaint within 1 year after screening of film in Chicago, which was within the 1-year statute of limitations. Remanded to trial court for further proceedings.(THEIS, NEVILLE, OVERSTREET, and CARTER, concurring.)
Illinois Supreme Court
Civil Court
Statute of Limitations