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Public official plaintiff failed to produce sufficient evidence of actual malice and failed to show that the statements in question were directed at him individually or that they were false.
We affirm the circuit court’s orders granting summary judgment to Councilman McCall and Councilwoman Cammick and denying the motion to amend.
In this defamation action, appellant David T. Stokes, a public-official plaintiff, sought review of the circuit court’s rulings granting summary judgment to respondents Wayne McCall and Edda Cammick and denying Stokes’ motion to amend his complaint. Stokes also challenged the circuit court’s ruling quashing a subpoena Stokes served on the Administrator for Respondent Oconee County. Stokes argued that Councilman McCall and Councilwoman Cammick were not entitled to immunity under the South Carolina Tort Claims Act because their alleged misconduct fell outside the scope of these council members’ official duties; the proposed amendment to his complaint would not have been futile because the alleged defamatory statements were not material to the purpose of the meeting at which they were made; and Stokes was entitled to serve a subpoena on the County Administrator in his individual capacity because his prior deposition was taken in his capacity as a representative of the County pursuant to Rule 30(b)(6), SCRCP.
Stokes failed to produce sufficient evidence of actual malice and failed to show that the statements in question were...
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