White v. Fraternal Order of Police

Robert White (plaintiff) served as a lieutenant in the Washington, D.C., Metropolitan Police Department (MPD). As part of White’s promotion to captain, he underwent a routine drug test at the MPD clinic. White’s urine sample tested positive for marijuana. However, White was still promoted to MPD captain. The Fraternal Order of Police (Order) (defendant) published a letter stating that White’s initial test was positive and, because the results were so high, the test should have been easily confirmed. The letter explained that the MPD followed abnormal testing procedures and follow-up testing of two urine samples returned as negative. The letter also generally discussed unusual testing procedures in connection with personal gain, specifically referencing promotions, and then immediately mentioned bribery laws. White was the only person named in the letter who experienced irregularities in testing and was promoted. White sued the Order for defamation. White admitted the facts as recited in the letter were substantially true but argued that true information is still capable of defamatory meaning through implication. White alleged the two defamatory inferences implied in the letter were that White used illegal drugs and that he used bribery to get his promotion. The district court granted a motion for summary judgment in favor of the Order. White appealed.