A Man Named Michael Scott
An award of punitive damages was upheld by the Maryland Court of Special Appeals
According to the testimony at the hearing on damages, Ms. Coronel dated a man named Michael Scott “off and on from 2012 to 2015.” The conclusion of that relationship coincided with Ms. Coronel seeking $110,000 from Mr. Scott in unrelated litigation in the Circuit Court for Baltimore City. In late 2015, Mr. Scott met and subsequently began dating Ms. Harvey-Jones.
At some point thereafter, someone began to harass Mr. Scott by anonymously sending him e-mails and text messages. Believing the culprit was Ms. Coronel, Mr. Scott hired Steve Brown, a private investigator. In late February 2016, Ms. Harvey-Jones sent Mr. Scott a text message stating that Ms. Coronel was the person who had been harassing him, and that Ms. Coronel had also sent over 300 e-mails to the local NBC news affiliate, resulting in her owing NBC $17,000 in damages. Ms. Harvey-Jones’s text message also contained a statement of charges which purported to show that Ms. Coronel had been charged with harassment as a course of conduct, electronic mail harassment, and telephone misuse. Believing the text message to be true, Mr. Scott forwarded it to his private investigator. Mr. Brown then met with Baltimore County Police Detective Larry Rogers, the officer who purportedly authored the charging document, to verify the contents of the text message.
When Detective Rogers saw the charging document, he suspected it to be counterfeit. He noted that the charging language, dates, and some of the applicable criminal codes were missing, and he also knew that he had never charged Ms. Coronel with harassment. Detective Rogers reviewed the tracking number from the charging document and determined that the tracking number and harassment charges matched a statement of charges he had filed in 2015 against Ms. Harvey-Jones. To be certain, Detective Rogers then searched Ms. Coronel’s criminal record, and verified that she had never been charged with harassment.
Near the end of March 2016, Mr. Brown informed Mr. Scott that Ms. Harvey-Jones’s text was inaccurate, that the charging document was fake, and that Ms. Coronel had neither harassed NBC with 300 e-mails, nor did she ever owe NBC $17,000 in damages.
Detective Rogers arrested Ms. Harvey-Jones in July 2016, and charged her with forgery of a public document. A local news website, Eye on Annapolis, posted a story about Ms. Harvey-Jones’s arrest. In the comments section of the article, a person named “Jane Shims” claimed that “someone [was] lying or misrepresenting” what had transpired and that Ms. Coronel was “a bitter ex.” Detective Rogers traced the IP address for Jane Shims, as well as other “people” who had commented on the article. He determined that the IP addresses for Jane Shims and several other commenters all belonged to a computer in Ms. Harvey-Jones’s home.
Ms. Coronel sued for defamation and secured compensatory and punitive damages.
The court sustained the punitive award
counterfeiting a public document is a felony under Maryland law carrying a penalty of two to ten years’ imprisonment. Given the seriousness of Ms. Harvey-Jones’s misconduct, we decline to disturb the circuit court’s award of punitive damages under this factor.
(Mike Frisch)