Handberg v. Goldberg

OPINION BY ELIZABETH A. McCLANAHAN

Michael N. Handberg appeals a decision of the trial court upholding a jury verdict finding him liable for defamation of Dr. Felicia Goldberg. We agree with Handberg that the trial court erred in its gatekeeping function by failing to properly instruct the jury as to actionable statements of fact versus statements that were merely opinion and thus nonactionable. We reverse and remand.

I. BACKGROUND

Handberg retained Dr. Goldberg to provide educational advocacy services for his son who attended Loudoun County Public Schools ("LCPS"). The Morgan Center, an…