By: Derek Hawkins//May 16, 2018//
WI Court of Appeals – District II
Case Name: Thaddeus Martin Lietz v. Daniel Frost
Case No.: 2016AP2030
Officials: Reilly, P.J., Gundrum and Hagedorn, JJ.
Focus: Defamation Claim
Thaddeus Lietz filed a complaint alleging that Daniel Frost—a next door neighbor of Lietz’s parents—made defamatory remarks against him to his parents and within earshot of others. Among the more sensational of these statements was an accusation by Frost that Lietz had been peeking in Frost’s window and masturbating. The circuit court granted summary judgment to Frost. Although we agree that the court properly dismissed three of Lietz’s defamation claims, we conclude that one of Lietz’s claims was actionable per se, meaning Lietz was not required to prove special damages (the failure of which served as one of the circuit court’s grounds for dismissing this claim). Therefore, we reverse the circuit court’s order dismissing that claim and remand for further proceedings consistent with this opinion.