{ "id": 2680138, "name": "JACK HABERSTROH, Plaintiff-Appellant, v. CRAIN PUBLICATIONS, INC., et al., Defendants-Appellees", "name_abbreviation": "Haberstroh v. Crain Publications, Inc.", "decision_date": "1989-09-25", "docket_number": "No. 1\u201487\u20142384", "first_page": "267", "last_page": "274", "citations": [ { "type": "official", "cite": "189 Ill. App. 3d 267" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "523 N.E.2d 179", "category": "reporters:state_regional", "reporter": "N.E.2d", "opinion_index": 0 }, { "cite": "168 Ill. App. 3d 603", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3514391 ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/168/0603-01" ] }, { "cite": "503 N.E.2d 580", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1988, "pin_cites": [ { "page": "583" } ], "opinion_index": 0 }, { "cite": "151 Ill. App. 3d 888", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3539101 ], "weight": 2, "year": 1988, "pin_cites": [ { "page": "893-94" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/151/0888-01" ] }, { "cite": "105 S. Ct. 2662", "category": "reporters:federal", "reporter": "S. Ct.", "opinion_index": 0 }, { "cite": "86 L. Ed. 2d 278", "category": "reporters:federal", "reporter": "L. Ed. 2d", "opinion_index": 0 }, { "cite": "471 U.S. 1127", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6396578, 6396796, 6396108, 6395933, 6396915, 6396342, 6397079, 6396246, 6396666, 6396028, 6396445, 6397271 ], "opinion_index": 0, "case_paths": [ "/us/471/1127-07", "/us/471/1127-09", "/us/471/1127-03", "/us/471/1127-01", "/us/471/1127-10", "/us/471/1127-05", "/us/471/1127-11", "/us/471/1127-04", "/us/471/1127-08", "/us/471/1127-02", "/us/471/1127-06", "/us/471/1127-12" ] }, { "cite": "750 F.2d 970", "category": "reporters:federal", "reporter": "F.2d", "case_ids": [ 628946, 3805683 ], "year": 1985, "opinion_index": 0, "case_paths": [ "/f2d/750/0970-01", "/us-app-dc/242/0301-01" ] }, { "cite": "457 N.E.2d 494", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1984, "opinion_index": 0 }, { "cite": "119 Ill. App. 3d 987", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3628182 ], "year": 1984, "opinion_index": 0, "case_paths": [ "/ill-app-3d/119/0989-01" ] }, { "cite": "418 U.S. 323", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6173012 ], "weight": 3, "year": 1986, "opinion_index": 0, "case_paths": [ "/us/418/0323-01" ] }, { "cite": "243 N.E.2d 217", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1982, "pin_cites": [ { "page": "219-20" } ], "opinion_index": 0 }, { "cite": "41 Ill. 2d 345", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2852216 ], "weight": 2, "year": 1982, "pin_cites": [ { "page": "347" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/41/0345-01" ] }, { "cite": "35 N.E.2d 517", "category": "reporters:state_regional", "reporter": "N.E.2d", "opinion_index": 0 }, { "cite": "311 Ill. App. 117", "category": "reporters:state", "reporter": "Ill. App.", "case_ids": [ 3380873 ], "opinion_index": 0, "case_paths": [ "/ill-app/311/0117-01" ] }, { "cite": "681 F. Supp. 55", "category": "reporters:federal", "reporter": "F. Supp.", "case_ids": [ 7396588 ], "pin_cites": [ { "page": "63" } ], "opinion_index": 0, "case_paths": [ "/f-supp/681/0055-01" ] }, { "cite": "290 N.E.2d 675", "category": "reporters:state_regional", "reporter": "N.E.2d", "opinion_index": 0 }, { "cite": "8 Ill. App. 3d 319", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2758027 ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/8/0319-01" ] }, { "cite": "401 N.E.2d 984", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1972, "opinion_index": 0 }, { "cite": "81 Ill. App. 3d 744", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3228866 ], "year": 1972, "opinion_index": 0, "case_paths": [ "/ill-app-3d/81/0744-01" ] }, { "cite": "477 N.E.2d 789", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1980, "opinion_index": 0 }, { "cite": "132 Ill. App. 3d 783", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3442739 ], "year": 1980, "opinion_index": 0, "case_paths": [ "/ill-app-3d/132/0783-01" ] }, { "cite": "418 U.S. 264", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6172714 ], "weight": 3, "opinion_index": 0, "case_paths": [ "/us/418/0264-01" ] }, { "cite": "398 U.S. 6", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 6169038 ], "weight": 3, "year": 1974, "opinion_index": 0, "case_paths": [ "/us/398/0006-01" ] }, { "cite": "419 N.E.2d 350", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1970, "pin_cites": [ { "page": "353" } ], "opinion_index": 0 }, { "cite": "83 Ill. 2d 146", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5473789 ], "weight": 2, "year": 1970, "pin_cites": [ { "page": "151" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/83/0146-01" ] }, { "cite": "237 N.E.2d 804", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1980, "opinion_index": 0 }, { "cite": "95 Ill. App. 2d 293", "category": "reporters:state", "reporter": "Ill. App. 2d", "case_ids": [ 2539241 ], "weight": 2, "year": 1980, "opinion_index": 0, "case_paths": [ "/ill-app-2d/95/0293-01" ] }, { "cite": "292 N.E.2d 138", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1968, "opinion_index": 0 }, { "cite": "9 Ill. App. 3d 217", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2846801 ], "weight": 2, "year": 1968, "opinion_index": 0, "case_paths": [ "/ill-app-3d/9/0217-01" ] }, { "cite": "442 N.E.2d 195", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "pin_cites": [ { "page": "199" } ], "opinion_index": 0 }, { "cite": "92 Ill. 2d 344", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3097134 ], "weight": 3, "pin_cites": [ { "page": "352" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/92/0344-01" ] }, { "cite": "181 N.E.2d 105", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1982, "opinion_index": 0 }, { "cite": "24 Ill. 2d 437", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2800594 ], "year": 1982, "opinion_index": 0, "case_paths": [ "/ill-2d/24/0437-01" ] }, { "cite": "252 N.E.2d 689", "category": "reporters:state_regional", "reporter": "N.E.2d", "pin_cites": [ { "page": "691" } ], "opinion_index": 0 }, { "cite": "115 Ill. App. 2d 229", "category": "reporters:state", "reporter": "Ill. App. 2d", "case_ids": [ 1588356 ], "pin_cites": [ { "page": "232" } ], "opinion_index": 0, "case_paths": [ "/ill-app-2d/115/0229-01" ] }, { "cite": "497 N.E.2d 1145", "category": "reporters:state_regional", "reporter": "N.E.2d", "weight": 2, "year": 1969, "pin_cites": [ { "page": "1147" } ], "opinion_index": 0 }, { "cite": "113 Ill. 2d 273", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3173376 ], "weight": 2, "year": 1969, "pin_cites": [ { "page": "277" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/113/0273-01" ] }, { "cite": "506 N.E.2d 1370", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1986, "pin_cites": [ { "page": "1374" } ], "opinion_index": 0 }, { "cite": "154 Ill. App. 3d 574", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3648457 ], "year": 1986, "pin_cites": [ { "page": "580" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/154/0574-01" ] }, { "cite": "467 N.E.2d 1090", "category": "reporters:state_regional", "reporter": "N.E.2d", "pin_cites": [ { "page": "1093" } ], "opinion_index": 0 }, { "cite": "126 Ill. App. 3d 563", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3596827 ], "pin_cites": [ { "page": "566" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/126/0563-01" ] }, { "cite": "457 N.E.2d 392", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1984, "pin_cites": [ { "page": "394" } ], "opinion_index": 0 }, { "cite": "99 Ill. 2d 24", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3163815 ], "year": 1984, "pin_cites": [ { "page": "27" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/99/0024-01" ] } ], "analysis": { "cardinality": 877, "char_count": 15152, "ocr_confidence": 0.789, "pagerank": { "raw": 6.581972043689836e-08, "percentile": 0.40290225414686337 }, "sha256": "c42009b421ac3b1f2843eb947e0420825521d947e138b41a4c2fd3c046cd0416", "simhash": "1:30b63d98add70355", "word_count": 2458 }, "last_updated": "2023-07-14T20:25:51.894502+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [], "parties": [ "JACK HABERSTROH, Plaintiff-Appellant, v. CRAIN PUBLICATIONS, INC., et al., Defendants-Appellees." ], "opinions": [ { "text": "JUSTICE BUCKLEY\ndelivered the opinion of the court:\nThis appeal arises from the circuit court\u2019s dismissal with prejudice of a libel action brought by Dr. Jack Haberstroh (plaintiff), an associate professor in the Department of Mass Communications at Virginia Commonwealth University in Richmond, Virginia, against Crain Communications, Inc., publisher of Advertising Age, Alan Pake, and Thomas J. Ryan (defendants). Plaintiff\u2019s three-count complaint alleged that portions of three letters published in Advertising Age were libelous. In dismissing plaintiff\u2019s complaint, the circuit court held that plaintiff\u2019s complaint did not adequately plead libel per se, as required where no special damages are alleged. We affirm.\nThe three letters, the subject of this appeal, were separately authored by Pake, Ryan and Anita Ludwig (not named as a defendant) and published by Crain in the November 11, 1985, and February 10, 1986, issues of Advertising Age in the section titled \u201cViewpoint: Letters.\u201d Each letter was written to the editor of Advertising Age in response to an article written by plaintiff and published in the \u201cPersonal Privilege\u201d section of the October 7, 1985, issue of Advertising Age. The article, entitled \u201cTone it down a bit, Lou,\u201d is described in plaintiff\u2019s complaint as questioning \u201csome of the methods used by advertising agencies in promoting products and expressing] reasons why individuals involved in advertising are not held in high esteem by the general public.\u201d The article strongly criticizes persons in the advertising industry. Among the statements made by plaintiff in the article are \u201cyou advertising cats are deliberately embedding vaginas, penises and orgies of every description in advertising art in order to sell products\u201d and that \u201cyour code of ethics is a laugh, followed by no one.\u201d\nIn count I of his complaint, plaintiff alleges that Crain and Pake defamed him by accusing him \u201cof being a communist and being incompetent in the performance of his duties as a professor.\u201d The complaint refers to Fake\u2019s letter:\n\u201cNo question \u2014 Haberstroh is a commie implant at old VCU. His mission is to overthrow the free enterprise system by poisoning its roots.\nWhy would anyone study a subject from a guy who obviously doesn\u2019t understand it?\u201d\nIn count II of his complaint, plaintiff alleges that Crain and Ryan defamed him by accusing him \u201cof committing a crime in that he uses illicit drugs.\u201d The complaint refers to a headline, which states \u201cAN ACID TRIP,\u201d and the accompanying letter written by Ryan:\n\u201c \u2018Tone it down a bit, Lou\u2019 written by Jack Haberstroh (Personal Privilege, AA Oct. 7) is certainly an indictment of all people working in the advertising profession. I am sure that many individuals reading this column had an ill feeling knowing that Mr. Haberstroh is an associate professor of advertising at Virginia Commonwealth University and his view of our profession is all that his young students will take away.\nMaybe Mr. Haberstroh should teach chemistry. I am sure he would recognize ACID when he sees it.\u201d\nFinally, in count III of his complaint, plaintiff alleges that Crain defamed him by accusing him of being \u201cmentally deranged and incompetent to perform his duties as a professor.\u201d The complaint refers to a letter written by Ludwig:\n\u201cTo Mr. Haberstroh\u2019s students, I would say: Run for your creative lives! This guy isn\u2019t travelling with a full set of luggage.\nTo all you creative ad pro\u2019s at or near retirement, I say: Get to a university and teach the next ad generation the real world of advertising.\u201d\nIn libel actions, proof of injury is not necessary where the alleged statement is libelous per se \u2014 where the words are \u201cobviously and naturally harmful.\u201d (Fried v. Jacobson (1983), 99 Ill. 2d 24, 27, 457 N.E.2d 392, 394; Renard v. Columbia Broadcasting System, Inc. (1984), 126 Ill. App. 3d 563, 566, 467 N.E.2d 1090, 1093.) Illinois courts have found four categories of words includible as \u201clibelous per se\u201d: (1) words which impute the commission of a criminal offense; (2) words which impute that one has a communicable disease which tends to exclude a person from society; (3) words which impute inability to perform or want of integrity in the discharge of duties of office or employment; and (4) words which prejudice a particular party in his profession or trade. Harris Trust & Savings Bank v. Phillips (1987), 154 Ill. App. 3d 574, 580, 506 N.E.2d 1370, 1374; Owen v. Carr (1986), 113 Ill. 2d 273, 277, 497 N.E.2d 1145, 1147; Bontkowski v. Chicago Sun-Times (1969), 115 Ill. App. 2d 229, 232, 252 N.E.2d 689, 691.\nSeveral well-established rules are applicable to the determination of whether statements are libelous per se within any of the above-mentioned categories. Illinois courts have followed the \u201cinnocent construction rule,\u201d established in John v. Tribune Co. (1962), 24 Ill. 2d 437, 181 N.E.2d 105, and modified in Chapski v. Copley Press (1982), 92 Ill. 2d 344, 442 N.E.2d 195. Under the original rule announced in John, words capable of being read innocently had to be so read. Chapski narrowed the rule in an attempt to strike a balance between the individual\u2019s interest in vindicating his good name and the importance of allowing the \u201cbreathing space\u201d essential to first amendment guarantees. The rule, as modified, requires the element of reasonableness:\n\u201c[A] written or oral statement is to be considered in context, with the words and the implications therefrom given their natural and obvious meaning; if as so construed, the statement may reasonably be innocently interpreted *** it cannot be actionable per se.\u201d (Chapski, 92 Ill. 2d at 352, 442 N.E.2d at 199.)\nIn construing words under the innocent construction rule, courts have developed other principles. Numerous Illinois cases have found words that are mere name-calling not to be actionable. (Delis v. Sepsis (1972), 9 Ill. App. 3d 217, 292 N.E.2d 138; Skolnick v. Nudelman (1968), 95 Ill. App. 2d 293, 237 N.E.2d 804.) Words found to be rhetorical hyperbole or employed only in a loose, figurative sense have also been deemed to be nonactionable. Catalano v. Pechous (1980), 83 Ill. 2d 146, 419 N.E.2d 350; Greenbelt Cooperative Publishing Association v. Bresler (1970), 398 U.S. 6, 26 L. Ed. 2d 6, 90 S. Ct. 1537; Old Dominion Branch No. 496, National Association of Letter Carriers v. Austin (1974), 418 U.S. 264, 41 L. Ed. 2d 745, 94 S. Ct. 2770.\nApplying these established rules to the case at bar, we consider plaintiff\u2019s contention that the statements in the three letters constitute libel per se. Plaintiff argues that under their plain and ordinary meaning, the three letters refer to plaintiff\u2019s occupation, question his capability as a teacher, and tend to prejudice plaintiff in his profession, while Ryan\u2019s letter further accuses him of committing a crime. Viewing the statements in their appropriate context, we find that the circuit court did not err in concluding the statements were not libelous per se, as the statements may reasonably be innocently construed as hyperbolic rhetoric of the viewpoints espoused in plaintiff\u2019s article.\nThe label \u201ccommie\u201d as used in the context of Pake\u2019s letter, unlike the cases cited by plaintiff, Resudek v. Sberna (1985), 132 Ill. App. 3d 783, 477 N.E.2d 789, Savage v. Seed (1980), 81 Ill. App. 3d 744, 401 N.E.2d 984, and McGuire v. Jankiewicz (1972), 8 Ill. App. 3d 319, 290 N.E.2d 675, does not imply a specific wrongdoing or directly attack plaintiff\u2019s integrity or competence in his profession. The statement clearly was made in response to a public debate initiated by plaintiff and in response to plaintiff\u2019s views of the advertising industry. A reasonable interpretation of this statement is that it figuratively expresses a belief that plaintiff\u2019s views are outside the mainstream. The second part of the Pake letter, \u201c[w]hy would anyone study a subject from a guy who obviously doesn\u2019t understand it?\u201d likewise could reasonably be innocently construed as an assessment of the merits of plaintiff\u2019s views.\nLudwig\u2019s statement, \u201c[r]un for your creative lives \u2014 This guy isn\u2019t travelling with a full set of luggage,\u201d also is not libelous per se. Because language may be abusive does not make it libelous per se. Courts have found similar language to be nonactionable as mere \u201cname-calling.\u201d (Skolnick v. Nudelman (1968), 95 Ill. App. 2d 293, 237 N.E.2d 804 (statements that the plaintiff was a \u201cnut,\u201d a \u201cmishuginer,\u201d and a \u201cscrewball\u201d); Delis, 9 Ill. App. 3d 217, 292 N.E.2d 138 (statements consisting of \u201cdishonorable,\u201d \u201cdeluded,\u201d and \u201cliar\u201d); Thomas v. News World Communications (D.D.L. 1988), 681 F. Supp. 55, 63 (statements including \u201cbum,\u201d \u201cpitiable,\u201d \u201clunatic,\u201d \u201cdeluded,\u201d and \u201cinsane\u201d).) The phrase used in the case at bar, \u201cnot travelling with a full set of luggage,\u201d clearly is an appraisal of plaintiff\u2019s views placed in his article and not a direct assault on plaintiff as a teacher. Although the phrase is admittedly abusive, it is mere name-calling and not so obviously and naturally harmful as to constitute libel per se.\nTurning to the letter written by Ryan and its accompanying headline, plaintiff argues that the headline \u201cAN ACID TRIP\u201d and the language \u201cI am sure [plaintiff] would recognize ACID when he sees it\u201d imputes that plaintiff uses illicit drugs.\nWhile we acknowledge that words in a headline are to be read in conjunction with the language that follows (Kulesza v. Chicago Daily News, Inc. (1941), 311 Ill. App. 117, 35 N.E.2d 517) and that the language need not express the commission of the offense in terms of art or with the particularity of an indictment to be libelous per se (Zeinfeld v. Hayes Freight Lines, Inc. (1968), 41 Ill. 2d 345, 243 N.E.2d 217, rev\u2019d on other grounds (1982), 92 Ill. 2d 344), we do not believe the two impute that plaintiff uses illicit drugs. Considering their context, a reasonable construction, as with the previously discussed letters, is that they refer to a reader\u2019s response to an article written by plaintiff and are not a personal account of plaintiff\u2019s activities. As defendants Ryan and Crane point out, the term \u201cacid\u201d may be reasonably construed as a satirical play on the definitions of the word. \u201cAcid\u201d is defined as \u201csomething incisive, biting or sarcastic\u201d and also as a chemical compound. In suggesting that plaintiff should teach chemistry because he is familiar with \u201cacid,\u201d the author plays on the biting, incisive ideas in plaintiff\u2019s article.\nThe cases plaintiff cites in support of his contention are distinguishable from the instant case in that the language in those cases did not have an alternative, reasonable construction. In Catalano (83 Ill. 2d at 151, 419 N.E.2d at 353), the defendant, speaking about certain aldermen, stated, \u201c[t]wo hundred forty pieces of silver changed hands, thirty for each alderman.\u201d The only reasonable interpretation of the language there was that it implied that the aldermen accepted bribes. The defendant in Zeinfeld (41 Ill. 2d at 347, 243 N.E.2d at 219-20), in response to an inquiry regarding the plaintiff\u2019s employment status as a comptroller, stated that after the plaintiff had left the company, \u201cwe discovered there was a substantial amount of money owed the company. Upon tracing [plaintiff] he offered to compromise.\u201d Clearly, the only reasonable construction of these statements is that the plaintiff had performed a criminal act in acquiring his employer\u2019s money.\nAccordingly, because Ryan\u2019s letter and accompanying headline may be reasonably innocently construed, we hold that they are not libelous per se under either the first or fourth per se categories.\nApart from our finding that the statements in issue are not libelous per se, we hold that the statements here are nonactionable because they are constitutionally protected expressions of opinion. It is an established first amendment principle that expressions of opinion are protected forms of speech no matter how vigorously the opinion is expressed. (Gertz v. Robert Welch, Inc. (1974), 418 U.S. 323, 41 L. Ed. 2d 789, 94 S. Ct. 2997; Owen v. Carr (1986), 113 Ill. 2d 273, 497 N.E.2d 1145; Howell v. Blecharczyck (1983), 119 Ill. App. 3d 987, 457 N.E.2d 494.) The crucial inquiry where first amendment rights are asserted in this context is whether the statement is an opinion or fact. Illinois courts have followed the totality-of-the-circumstances analysis, developed in Ollman v. Evans (D.C. Cir. 1984), 750 F.2d 970, cert, denied (1985), 471 U.S. 1127, 86 L. Ed. 2d 278, 105 S. Ct. 2662, to serve as a guideline in making this determination. (Stewart v. Chicago Title Insurance Co. (1987), 151 Ill. App. 3d 888, 503 N.E.2d 580; Horowitz v. Baker (1988), 168 Ill. App. 3d 603, 523 N.E.2d 179.) This analysis, as interpreted in Stewart, consists of the following:\n\u201cThe first test is whether the common usage or meaning of the specific terms or language has a precise core of meaning for which a consensus of understanding exists or, conversely, whether the statement is indefinite or ambiguous. The second test requires the court to look at the defamatory statement from the viewpoint of a reasonable reader to determine if that reader believes the statement to have a specific factual content making it believable. The third test requires that the court consider the full context of the statement to see if the surrounding language will influence the average reader\u2019s readiness to infer that a particular statement has factual content. The fourth test requires the court to consider the broader context or setting in which the statement appears, specifically the type of writing in which the statement is found and the people to whom the writing is distributed.\u201d Stewart, 151 Ill. App. 3d at 893-94, 503 N.E.2d at 583.\nThe three letters in the case at bar were clearly written in response to a debate initiated by plaintiff in writing a controversial article. The letters were published in the \u201cletters to the Editor\u201d section of the publication, traditionally the forum for expressions of opinion. None of the language in the letters could be reasonably read to imply the writer\u2019s personal knowledge of any specific misconduct or of plaintiff\u2019s abilities as a teacher. Viewed in their entirety and context, a reasonable reader would not believe that any of the statements have specific factual content, but would believe the statements were expressions of opinion as to the views expressed in plaintiff\u2019s article.\nFor the foregoing reasons, the order of the circuit court of Cook County is affirmed.\nAffirmed.\nMANNING, P.J., and CAMPBELL, J., concur.", "type": "majority", "author": "JUSTICE BUCKLEY" } ], "attorneys": [ "Walsh, Neville, Pappas & Mahoney, of Chicago (George Pappas, of counsel), for appellant.", "Jenner & Block, of Chicago (David P. Sanders and Kevin P. Whaley, of counsel), for appellees Crain Publications, Inc., and Advertising Age.", "Querry & Harrow, Ltd., of Chicago (Michael Resis and Victor J. Piekarski, of counsel), for appellee Alan Pake.", "Tuohy & Martin, Ltd., of Chicago (James L. Tuohy, of counsel), for appellee Thomas J. Ryan." ], "corrections": "", "head_matter": "JACK HABERSTROH, Plaintiff-Appellant, v. CRAIN PUBLICATIONS, INC., et al., Defendants-Appellees.\nFirst District (1st Division)\nNo. 1\u201487\u20142384\nOpinion filed September 25, 1989.\nWalsh, Neville, Pappas & Mahoney, of Chicago (George Pappas, of counsel), for appellant.\nJenner & Block, of Chicago (David P. Sanders and Kevin P. Whaley, of counsel), for appellees Crain Publications, Inc., and Advertising Age.\nQuerry & Harrow, Ltd., of Chicago (Michael Resis and Victor J. Piekarski, of counsel), for appellee Alan Pake.\nTuohy & Martin, Ltd., of Chicago (James L. Tuohy, of counsel), for appellee Thomas J. Ryan." }, "file_name": "0267-01", "first_page_order": 289, "last_page_order": 296 }