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Determining Reasonable Accommodation for Pro Se Litigants
Idlibi v. Hartford Courant Company is instructive on how a self-represented party should be treated in court.
October 14, 2024 at 05:23 PM
4 minute read
CommentaryThe recently decided case of Idlibi v. Hartford Courant Company (SC 20800) is a law school class on how a self-represented party should be treated in Connecticut's courts. Both the decision, by Justice McDonald, and the dissent, by Justices Ecker and D'Auria, are exhaustive, going into excruciating detail on the rights and obligations of the party who chooses to represent him or herself and how the courts should deal with that party. Given that both parts of the decision are so thorough and so well-presented, the result is that from a precedential standpoint, the argument is still out there, largely undecided, although the decision itself has obviously been made by a majority of the court.
The facts are not complicated. A pediatric dentist is accused of malpractice for work done on a small child without the parent's permission. Two articles in the Hartford Courant relate the facts and the decisions of the Department of Public Health and the State Dental Commission, fining the dentist and putting his Connecticut license to practice as a dentist on probation. Dr. Idlibi then brought suit against the Hartford Courant for defamation, claiming that the stories unfairly represented the facts of the case. The matter proceeded quickly to summary judgment, and then to appeal, where the Appellate Court upheld the decision in favor of the newspaper, finding that the articles were substantially true or subject to the fair report privilege. What was missing was a claim, poorly presented by the plaintiff, that a photograph that accompanied both articles was also defamatory, or, in the plaintiff's words, was misleading and brought with malice.
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