Yelp Review Exposes Plastic Surgery Patient to Defamation Claim

A California plastic surgeon may proceed on his defamation claim against a former patient who wrote in a Yelp.com review that he “screwed up so badly” that it took 10 later surgeries to correct the problem, a California appeals court said.

Much of Valerie Swan’s review of Paymon Simoni consisted of nonactionable opinion, the California Court of Appeal, Second District said. But her statement that he “screwed up so badly” was one of fact that could be proven false and thus was actionable, it said in an unpublished opinion.

The court affirmed a lower court decision denying Swan’s motion to ...