Royer

Defendants-appellants Ralph J. Steinberg, Richard MacQuiddy and Eleanor Graham-Armstrong (appellants) appeal from a judgment against them and in favor of plaintiff-respondent Neal Royer (Royer) in the amount of $200,000 jointly in compensatory damages and $2,000, $2,000 and $300 respectively in punitive damages. The judgment is the result of an action for libel and conspiracy to libel stemming from statements made by appellants in a motion passed by them as members of the board of trustees of a school district.

Statement of Facts

At all times pertinent to the instant controversy, appellants were the elected trustees of the Campbell Union School District, serving without compensation. Royer began teaching in the school district in 1948, became a principal in 1952, and was appointed superintendent in 1965.

Shortly prior to the April 15, 1969, trustee election in which appellants Steinberg and Graham-Armstrong were running, certain flyers circulated throughout the district purporting to originate from the Campbell Elementary Teachers Association (CETA). The flyers made false and derogatory statements ostensibly in support of the election and reelection of appellants…