Couch

Plaintiff Alfred O. Couch worked as a campus security officer, or “monitor,” at Rio Americano High School in Carmichael. On arriving at work on the morning of February 28, 1992, he was shown a portion of an article in that day’s edition of the school newspaper. He concluded, without reading the rest of the article, that it accused him of being, among other things, a murderer and a drug dealer. Despite the apologies of the article’s authors, he resigned his position, claiming that he could no longer feel comfortable working at the school. He then sued defendant San Juan Unified School District (the District), which operates Rio Americano High School, alleging libel, invasion of privacy, and emotional distress. The second and third counts were dismissed on demurrer; the libel count fell to defendant’s motion for summary judgment. Plaintiff appeals, seeking the reinstatement of all three counts. We shall affirm.

Facts

Plaintiff was first employed as a campus monitor at Rio Americano High School in 1991. Following a leave of absence, he returned to work on February 11, 1992. From February 11, 1992, to February 28, 1992, he was the only African-American employee at the…