Spencer v. Klementi
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The Supreme Court affirmed in part and reversed in part the orders of the district court granting summary judgment to Respondents on Appellant's defamation claims and malicious-prosecution claim, holding that the district court erred in relying on the judicial-proceedings privilege in granting summary judgment for Respondents on Appellant's defamation claim based on certain statements.
Appellant sued Respondents for defamation based on statements Respondents made during the public comment period of planning commission an improvement district meetings. Appellant also sued for malicious prosecution after he was acquitted on battery and elder abuse charges. The district court granted summary judgment for Respondents. The Supreme Court reversed in part, holding (1) the judicial-proceedings privilege extends to statements made during quasi-judicial proceedings, but the public comment portions of the meetings in this case were not quasi-judicial, and therefore, the district court erred in relying exclusively on this privilege in granting summary judgment; (2) the district court correctly granted summary judgment on Appellant's defamation claims that relied on statements that were undisputedly true; and (3) the district court did not err in applying the law in resolving the malicious prosecution claim.
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