After a four-year legal battle, a Connecticut federal judge dismissed a $50 million lawsuit brought against Yale by Dongguk University.
The Korean university sued Yale in March 2008 for verifying the authenticity of Dongguk art history professor Shin Jeong-ah’s forged Yale doctorate degree and later denying the error had occurred. The story drew national attention in South Korea, leading to the resignations of Dongguk’s president and board of trustees, and the university claimed Yale’s negligence cost it millions in project cancellations and damage to its reputation.
Yale later acknowledged that an administrative error led to a false confirmation, though the University has repeatedly claimed the negligence suit lacked merit. The University made two previous motions to dismiss the case in August 2011 and February 2012, and while both attempts failed, Judge Tucker Melançon withdrew his ruling on the February 2012 motion, claiming the ruling “overlooked” arguments about the burden of proof for defamation and negligence.
“The Court erred as a matter of law in the [February 2012 ruling] by applying the lesser standard of proof, preponderance of the evidence, rather than the proper standard of proof, clear and convincing evidence,” Melançon said in a decision filed Friday.
According to Melançon’s new standard of proof, “a failure to investigate by itself is not enough to prove actual malice” unless the failure was a willful avoidance of the truth. Yale’s mistaken confirmation did not meet that standard, according to the decision.
The judge also ruled that a defendant’s refusal to admit that an allegedly defamatory statement was inaccurate “does not establish that he realized the inaccuracy at the time of publication,” meaning that Yale’s initial denial of its false confirmation was not necessarily malicious either.
Without proving malice, a jury could not find in favor of Dongguk, Melançon said, adding there was not enough evidence for a jury to reasonably find proof without speculation. Melançon then dismissed the case, claiming “there could be but one verdict that a jury of reasonable persons could reach: a verdict in favor of Yale and against Dongguk on all of Dongguk’s remaining claims.”
“We are very pleased with Judge Melançon’s decision dismissing the case. We have always believed that this case was without legal merit,” University spokesman Tom Conroy said in a Monday email.
Robert Weiner, an attorney representing Dongguk, said that he and his legal team were “extremely surprised” at the decision and that they planned to review it, according to the Associated Press. Weiner declined comment to the News on Monday.
Shin was convicted of forging her Yale degree, along with two others from the University of Kansas, and served 18 months in prison.