Zeran v. Diamond Broadcasting, Inc.

After the 1995 Oklahoma City bombing, an AOL user posted listings for offensive bombing-themed shirts and gave the business phone number of Kenneth Zeran (plaintiff), a Seattle artist with no connection to the posts. Zeran was flooded with threatening calls. About a week later, hosts on KRXO, a radio station owned by Diamond Broadcasting (defendant), discussed the posting on air, read the phone number, and urged listeners to call and tell 'him' what they thought. Zeran received roughly 80 angry calls, including death threats, and was prescribed anti-anxiety medication. KRXO later aired a retraction at his request. Zeran sued Diamond for defamation; the district court granted summary judgment for Diamond, finding Zeran failed to prove the elements, and he appealed.

Whether a plaintiff must prove an injury to his reputation to support a defamation (slander per quod) claim.