Appellant Was Entitled to Special Damages in Defamation Action Where He Showed that Lease Was Terminated Because of Defamatory Statements

The appellant and the respondent were friends who shared farming equipment and occasionally stored equipment on each other's property. After the parties had a "falling out," the appellant commenced an action against the respondent for conversion, trespass, and defamation.  The respondent filed an answer to the complaint, admitting that he converted the appellant's property, defamed appellant, and trespassed on the appellant's land, causing damage. Based on the answer, the appellant filed a motion for judgment on the pleadings and a motion for summary judgment. The district court granted the motion as to liability and causation, but ordered a trial for the issue of damages. After a bench trial, the trial court awarded the appellant $2,000 in general damages for the defamation and $2,000 for the conversion.  The appellant challenged the award, arguing that he was entitled to the $50,200 in damages asserted in his pleading. He asserted that the trial court erred in refusing to award him special damages. The court affirmed as to the award of general damages award, but reversed and remanded as to the issue of special damages. The appellant had offered testimony establishing that the defamation was a substantial factor in bringing about the termination of a lease. On remand, the trial court was to determine the amount of special damages established by the appellant. Green v. Kellen, No. A13-1554, 2014 Minn. App. Unpub. LEXIS 514 (Minn. Ct. App. May 27, 2014).