Employment & Labor Law for Public Safety Agencies

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     After the Massachusetts governor removed the chair of the state Sex Offender Registry Board (SORB), he made statements to the media concerning his reasons for doing so, including allegations that she had interfered with the independence of a SORB hearing officer. She sued the state for wrongful termination and the governor for defamation. The highest court in the state ruled that the defamation claims should be dismissed, since the plaintiff did not allege facts that were sufficient to establish that the governor made false statements about her with “actual malice,” the required legal standard in a defamation claim against a public official. Regardless of the governor's alleged spiteful, negative feelings toward the plaintiff, she was still required to allege specific facts to prove that the governor made his statements to the media with actual malice, knowledge of their falsity, or with reckless disregard of their truth or falsity. Edwards v. Commonwealth, #SJC-12175, 477 Mass. 254, 2017 Mass. Lexis 374.

    A police officer fiiled a written complaint with his chief, reporting that fellow officers and county sheriff's deputies had been racially profiling minority citizens and committing other constitutional violations. As a result, he claimed, among other retaliatory actions, a be-on-the -lookout advisory (“BOLO”) to all law enforcement in Douglas County, Georgia, described him as a “loose cannon.” “Consider this man a danger to any [law enforcement officer] in Douglas County and act accordingly,” the BOLO alarmingly warned and ominously instructed. He had previously been terminated as an officer, but appealed that decision, again repeating his allegations. The BOLO was issued the day after the termination appeal hearing by a major with the county sheriff's office. After the BOLO was issued, his car was allegedly followed by both police and sheriff's vehicles. He was later allowed to return to work as an officer. He sued the major in his official and individual capacities for defamation and retaliation in violation of his First Amendment rights. Rejecting defenses of qualified immunity on the First Amendment retaliation claim and official immunity by the defendant major on the defamation claim, the appeals court found that the plaintiff's alleged facts would support a reasonable inference that the police department communicated with the Sheriff’s Department about the plaintiff's complaints prior to the issuance of the be-on-the-lookout advisory (BOLO), that the Sheriff’s Office and the major knew about the termination-appeal hearing, and that the major issued the BOLO at least in part in retaliation for plaintiff's complaints, in violation of the First Amendment. The court also ruled that the plaintiff's constitutional right to be free from retaliation that imperiled his life was clearly established at the time that the BOLO was issued. The allegations satisfied the showing of a deliberate intention to do wrong—that is, actual malice. "Our First Amendment demands that a law enforcement officer may not use his powerful post to chill or punish speech he does not like. If he does so, he may not hide behind the veil of qualified immunity." Bailey v. Major Tommy Wheeler, #15-11627, 2016 U.S. App. Lexis 21194 (11th Cir.).
     Two employees of the U.S. Department of Homeland Security (DHS) sued a local police chief for slander and interference with advantageous business relations after he called another DHS agent to complain about their allegedly "unprofessional" behavior during an encounter. The grant of summary judgment to the defendant on both claims was upheld by a federal appeals court. The allegedly defamatory statements amounted to non-actionable opinions, and the chief fully disclosed the non-defamatory facts about the confrontation in a way that enabled the DHS agent contacted to form his own opinion. Piccone v. Bartels, #14-1989, 2015 U.S. App. Lexis 7582 (1st Cir.).
     The Chief Deputy Register of Deeds fr a county sought an interim appointment from the governor for the Register when that position, normally elected, became vacant. After the governor's appointment secretary interviewed her, he became aware that she was involved in a personal bankruptcy and informed her that she would not be appointed. She alleged that the governor's official spokesman and the governor defamed her by publically making statements that she was not appointed because she was in a bankruptcy proceeding. She asserted claims for violation of privacy rights, employment rights, and bankruptcy discrimination under 11 U.S.C. Sec. 525(a). A federal appeals court found that the defendants were entitled to qualified immunity on both her privacy and equal protection claims. Chasensky v. Walker, #13-1761, 2014 U.S. App. Lexis 1160 (7th Cir.).
     After a correctional employee was demoted for violating a state travel billing policy, the department's Commissioner responded to media questions about the demotion. The employee sued for defamation. The Tennessee Supreme Court held that the state and cabinet level executive officials were absolutely immune from a defamation claim arising in this manner--for statements made while performing official duties. Jones v. State, #M2012-02546-SC-S09-CV, 2013 Tenn. Lexis 1013.
     Muslim police officer who was terminated after being questioned by the FBI for possible links to terrorist groups accepts a $125,000 from the city and school district. A flier with his police ID photo had been circulated in the local school district advising that he is "currently under investigation by the FBI for possible affiliation with a terrorist organization." Fernandes v. City of Fremont, Calif. [Cal. Govt. Code §910-913.2 claim]
     Wisconsin appellate court holds that workers' compensation is not the exclusive remedy for a former county employee, who brought a defamation lawsuit based on statements that were made after his resignation. Anderson v. Hebert, #2010AP1992, 2011 Wisc. App. Lexis 203.
     A public employee sued officials after an advertisement was published in the local newspaper that appeared to solicit applicants for his job. He was embarrassed and stressed by the newspaper ad and questions about it from people in town. In rejecting his claims, the Montana Supreme Court noted that his employment was not terminated, no one was hired to replace him, and he suffered no loss of wages. Jensen v. Absarokee W&S Dist., #DA 10-0039, 2010 MT 189N, 2010 Mont. Lexis 291 (unpub.).
     Federal court rules that calling someone a homosexual is not defamation per se. Stern v. Cosby, #1:07-cv-08536, PACER Doc. 138 (S.D.N.Y.).
     Illinois appellate panel finds that the First Amendment’s freedom of religion clause protects persons who testify against a priest in an internal disciplinary proceeding, and a defamation suit filed by the accused party must fail. Stepak v. Doe, #1-08-2140 (Catholic Bishop of Chicago), 2009 Ill. App. Lexis 513 (1st Dist.), citing Serbian E. Orth. Diocese v. Milivojevich, 426 U.S. 696 (1976).
     Although a misconduct complaint about another officer, sent to one's superiors, is absolutely privileged from defamation claims, but it is not immunized from liability if the allegations are revealed to officers outside the complainant's chain of command. It becomes a conditional privilege and is a question of fact for the jury as to whether the privilege was abused. Anderson v. Beach, #1-07-1911, 2008 Ill. App. Lexis 1047 (1st Dist.).
     Justice Dept. agrees to settle with scientist Stephen Hatfill, who was identified by then Attorney General Ashcroft as a "Person of Interest" in an investigation of the 2001 anthrax attacks on the Congress. Hatfill was followed 24/7 by FBI agents, and lost a $150,000 university teaching job on the order of Justice officials. The DoJ has agreed to pay Dr. Hatfill and his attorneys $2.825 million and to fund an annuity paying him $150,000 for life. Hatfill v. Mukasey (formerly Hatfill v. Ashcroft), #03-cv-1793, 2008 U.S. Dist. Lexis 17756 (D.D.C.); #08-5049, 2008 U.S. App. Lexis 5755 & 6242 (D.C. Cir.). View: Complaint and DoJ Press Release #08-576.
     A police chief had a triable defamation claim against the public safety director who published a report containing an inmate's allegation that the police chief had impregnated a juvenile prostitute; the director failed to learn that the chief had undergone a vasectomy. Jackson v. City of Columbus, #2006-2096, 2008-Ohio-1041, 117 Ohio St.3d 328, 883 N.E.2d 1060, 27 IER Cases (BNA) 516, 2008 Ohio Lexis 558.
     Florida appellate court overturns a defamation jury verdict in favor of a police officer against his lieutenant. The lieutenant was entitled to absolute immunity because his statements were within the scope of his authority and duties. Cassell v. India, #4D06-1716, 2007 Fla. App. Lexis 13001 (4th Dist.).
     Police chief's defamation claim against the mayor is dismissed, even if the mayor acted with malice, a defamation action against a city official for disciplining the plaintiff was barred by absolute immunity. Schultea vs. City of Patton Village, #H-06-0666, 2006 U.S. Dist. Lexis 78381 (S.D. Tex. 2006). {N/R}
     Appellate court rejects the claims of a police chief that he was defamed in a mayoral report. Jackson v. City of Columbus, #05AP-1035, 2006 Ohio App. Lexis 5166 (10th App. Dist. 2006). {N/R}
     Defamatory statements about a police chief contained in an investigative report ordered by the mayor were protected by the public interest privilege. Jackson v. City of Columbus, #05AP-1035, 2006 Ohio 5089, 2006 Ohio App. Lexis 5019 (10th App. Dist. 2006). {N/R}
     During a state police investigation, police employees' claims of injury to their reputations must fail because there were no adverse personnel actions, such as a loss of pay or benefits, changed working conditions, demotions or terminations. Heller v. Fulare, #04-265J, 2006 U.S. Dist. Lexis 69162 (W.D. Pa. 2006), on remand from 454 F.3d 174 (3d Cir. 2006). {N/R}
     Ex Florida deputy and his wife awarded $1,231,700 million against the county. The plaintiffs were falsely accused of bringing drugs into the jail -- and management allegedly botched the internal investigation. Femminella v. Palm Beach County, Docket #50-204 CA 002604, CFN 20060081517 (15th Circuit Court, Fla.). [2006 FP Jun]
    Fourth Circuit refuses to dismiss defamation suit brought by a former Army scientist who was identified as a "person of interest" in the 2001 anthrax killings. Hatfill v. N.Y. Times Co., #04-2561, 427 F.3d 253, 2005 U.S. App. Lexis 22397 (4th Cir. 2005). {N/R}
     Second Circuit affirms the dismissal of a lawsuit filed by 23 police officers who claimed that their reputations were harmed by the release of an internal investigative Report. None of the plaintiffs were named in the Report, and the chief was not a party to the lawsuit. Algarin v. Town of Wallkill, #04-2607, 421 F.3d 137, 2005 U.S. App. Lexis 18762 (2nd Cir. 2005). [2005 FP Nov]
     Canadian police chief receives a settlement of Can-$5,000 [US-$4,000] from a couple who anonymously published a web blog that that accused him of being a "rotten apple" and heading a "corrupt" administration. Beaton v. Fisher, Queen's Bench, Alberta. Source: CBC News and Calgary Sun (30 Apr. 2005). {N/R}
     Appellate court holds that a police officer and his wife could sue because of statements, made on a radio show, that he had stabbed another officer and had engaged in an extra-marital affair. The statements were defamatory per se because they alleged criminal activity and serious sexual misconduct. Gordon v. Boyles, #02CA2196, 99 P.3d 75 (Colo. App. 2004). {N/R}
     Internal performance reports of a probationary officer that were not made public cannot be the basis for a defamation claim. Luy v. Baltimore Police Dept., #CCB-03-2833, 326 F.Supp.2d 682 (D.Md. 2004). {N/R}
    Connecticut Supreme Court holds that citizen complaints made to an internal affairs office are protected from defamation lawsuits, even if deliberately false. Craig v. Stafford, #SC 17073, 271 Conn. 78, 856 A.2d 372, 2004 Conn. Lexis 361 (2004).[2005 FP Jan]
     Iowa Supreme Court sustains a verdict of $96,000 in compensatory and $60,000 in punitive damages for a woman deputy who sued a male deputy for sending an altered photo of her, in uniform, with her breasts exposed. The justices also reversed a trial court order dismissing the county and the sheriff from liability for negligent retention of the male officer. Kiesau v. Bantz, #03-0815, 686 N.W.2d 164, 2004 Iowa Sup. Lexis 229 and 256 (2004). [2004 FP Dec]
     Iowa Supreme Court holds that prosecutorial immunity does not apply to a county attorney who told a police chief and a mayor that he would not prosecute any cases involving the office because he had lied to investigators about his wife's death. The officer was fired and sued the county attorney for defamation, interference with employment contract, and unlawful dissemination of "intelligence data." Beck v. Phillips, #76/03-0645, 685 N.W.2d 637, 2004 Iowa Sup. Lexis 228 (Iowa 2004). {N/R}
     Appeals court rejects a defamation claim by a worker who was fired after a background investigation revealed possible criminal conduct. The signed release barred any lawsuit, even if the firm that oversaw the investigation did not have a state license to conduct investigations. McCleskey v. Vericon Resources, #A03A1066, 2003 Ga. App. Lexis 1376, 20 IER Cases (BNA) 1065 (2003). [2004 FP Feb]
     Federal court rejects a civil rights lawsuit filed by officers who complain that an internal investigation of the behavior was biased, but they may be able to prove that statements made by an investigator were defamatory. Keim v. Co. of Bucks, 275 F.Supp.2d 628, 2003 U.S. Dist. Lexis 13926 (E.D. Pa. 2003). [Dec FP 2003]
     Federal appeals court holds that a county is not liable under §1983 for public statements made by a member of the county board of commissioners concerning the job performance of a county employee. Also, under state law, the commissioner was entitled to absolute immunity for his statements. LaVerdure v. Co. of Montgomery, #02-2773, 2003 U.S. App. Lexis 6547 (3rd Cir. 2003). {N/R}
     Prison warden could not sue a Connecticut newspaper in Virginia for posting allegedly defamatory matter on its website. "A court in Virginia cannot constitutionally exercise jurisdiction over the Connecticut-based newspaper defendants because they did not manifest an intent to aim their websites or the posted articles at a Virginia audience." Young v. New Haven Advocate, #01-2340, 2002 U.S. App. Lexis 25535 (4th Cir. amended 2003). {N/R}
     Ninth Circuit upholds the right of a police officer to sue entertainer George Michael for slander and the intentional infliction of emotional distress. The singer accused the undercover officer of provoking Michael's lewd conduct in a public toilet. Rodriguez v. Panayiotou, #00-56923, 2002 U.S. App. Lexis 24352 (9th Cir. 2002). [2003 FP Feb]
     Federal appeals court rejects a libel action brought by a former FBI official who was accused of having advance knowledge about the 1998 Pan Am 103 bombing. Revell v. Hoffman, #01-6169, 2002 U.S. App. Lexis 22624 (10th Cir. 2002). [2003 FP Jan]
     Jury awards an applicant for a federal immigration officer position over $30,000 in compensatory and $500,000 in punitive damages against a former employer who falsely accused him of theft and revealing classified military information. Ake v. Hirazumi, #994566, 45 (9) ATLA L. Rptr. (Unpub. Hawaii Cir. Ct. 2002). {N/R}
     Public official was not entitled to a court order compelling a reporter to disclose his source for an allegedly defamatory article. Weinberger v. Maplewood Review, #C7-01-2021, 2002 Minn. App. Lexis 711 (Minn. App. 2002). {N/R}
     California appeals court strikes down a law that allowed peace officers to sue citizens for knowingly making a false complaint of misconduct. Walker v. Kiousis, #E029822, 93 Cal.App. 4th 1432, 2001 Cal. App. Lexis 2584, 114 Cal.Rptr.2d 69, 01 C.D.O.S. 10003 (4th Dist.). [2002 FP Mar]
     Court dismisses a suit of a former FBI agent who was involved the "Travelgate" investigation of White House staff, brought against a "media commentator," who made various statements regarding the agent in 1996. The agent was unable to show that the commentator acted with malice and the federal agent was a limited public figure. The commentator was entitled to a qualified privilege because there was a reasonable basis for his statements. Sculimbrene v. Reno, #99-2010, 158 F.Supp.2d 8, 2001 U.S. Dist. Lexis 12307 (D.D.C. 2001). {N/R}
     Illinois appeals court holds that complaints of coworker misconduct are absolutely privileged against lawsuits for reputational injuries. Busch v. Bates, #5-99-0638, 753 N.E.2d 1184, 2001 Ill. App. Lexis 596. [2001 FP 163]
     Appellate court allows a police sergeant to sue an officer for defamation and economic losses. The officer, of Japanese origin, had reported to management that the sergeant muttered "fucking gooks" in his presence. McNamee v. Jenkins, #98-P-2204, 52 Mass. App. 503, 2001 Mass. App. Lexis 883. {N/R}
     Sheriff Dept. that provided deputies to accompany a private employer for the purpose of firing employees was not defamatory. D'Errico v. DeFazio, 763 A.2d 424 (Pa. Super.). {N/R}
     Federal appeals court rejects a suit by a citizen seeking to overturn a California statute giving a law enforcement officer the right to sue citizens for making false complaints against them. Gritchen v. Collier, #99-56940, 2001 U.S. App. Lexis 12869 (9th Cir. 2001) reversing 73 F.Supp.2d 1148 (C.D. Cal. 1999). {N/R}
     Lawsuit filed by a former housing authority police officer for defamation is dismissed because of statutory immunity. King v. City of Chicago, #1-99-4123, 2001 Ill. App. Lexis 644 (1st Dist., 2001). {N/R}
     Federal appeals court rejects a suit against the city filed by a dispatcher who was fired for making a false crime report. City kept the details of her termination confidential and did not violate her reputational rights. Hughes v. City of Garland, #99-10482, 2000 U.S. App. Lexis 1789 (5th Cir.). [2000 FP 51]
     A town Selectman's statements about the chief of police were absolutely privileged from a claim for defamation, where the statements were made at town meeting, and involved an issue properly raised at a town meeting. Voelbel v. Town of Bridgewater, 747 A.2d 252, 1999 N.H. Lexis 161, 15 IER Cases (BNA) 1639 (N.H.). {N/R}
     A statute permitting police officers to sue for defamation those who falsely complain about them to their employers violates the First Amendment. Haddad v. Wall, 107 F.Supp.2d 1230. {N/R}
     Illinois appellate court allows a lawfully terminated sexual harasser to sue his superior and the employer for publicizing the reason for his dismissal. Parker v. Bank of Marion, 695 N.E.2d 1370, 1998 Ill.App. Lexis 390, 231 Ill. Dec. 251. [1998 FP 149]
     Calling a sarcoidosistic worker a "cocksucker with a two inch dick," a "dago guinea" or a "short, ugly and stupid Italian" was not defamatory. However, employer could be sued for a supervisor's same-gender harassing language, creating a hostile environment. Grillo v. John Alden Ins., 939 F.Supp. 685 (D.Minn. 1996). {N/R}
     Statements accusing police chief of official misconduct (including corruption, coverups and racial discrimination) were susceptible of defamatory meaning; councilman's statements were not "personal opinion." Scott v. Cooper, 640 N.Y.S.2d 248 (A.D. 1996). {N/R}
     S.C. Supreme Court upholds $750,000 defamation verdict awarded to an asst. police chief against the City Administrator. He was publicly accused of sexual harassment without just cause. Miller v. City of West Columbia, 1996 S.C. Lexis 86, 471 S.E.2d 683. [1996 FP 132]
     Suit against mayor for stating that a police applicant "flunked" the exam and was a "lunatic" fails. Suppan v. Kratzer, 660 A.2d 226 (Pa.Cmwlth. 1995). [1996 FP 60]
     Employer could be sued for defamation where the medium was internal company e-mail. Employer announced the plaintiff's termination to other employees, for "credit card fraud," where no fraud was intended by the employee. Meloff v NYLIC, 51 F.3d 372/at375-6 (2nd Cir. 1995). {N/R}
     Defamation suit was preempted by LMRA. Arbitration award reinstating the plaintiff precluded a state-law action for damages. Furillo v. Dana Corp., 150 LRRM 2785 (E.D.Pa. 1995); also see 866 F.Supp. 842 (1994). [1996 FP 35]
     Two police officers win $1.2 million for enduring false rumors they were romantically involved. City took more than a year to finish the investigation; EEOC requires employers to take prompt action. Baker v. City of Oceanside, San Diego Co. Super. Ct. #N56730, 33 (1605) G.E.R.R. 341 (1994); Simpson v. City of Oceanside, San Diego Co. Super. Ct. #N56726 (1994). [1995 FP 85]
     Statements made by workers to their employer during the course of an internal investigation are privileged communications and cannot be the subject of a suit for defamation, unless they were made with malice or ill will. Herlihy v. M.M.A., 214 A.D.2d 250, 633 N.Y.S.2d 106 (1995). {N/R}
     Appellate court reverses $80,000 judgment given an ex-employee who claimed it was defamation to terminate her for misconduct in front of her supervisor. Harrel v. Dillards, 644 N.E.2d 448, 1994 Ill.App. Lexis 1452. [1995 FP 68]
     "An employer enjoys a qualified privilege when commenting on personnel matters to those who have a legitimate and direct interest in the subject matter of the communication. A company's employees have a legitimate and direct interest in the reasons for a co-worker's dismissal." Esmark v. James, 10 F.3d 1156, 1994 U.S. App. Lexis 267, relying on state law announced in Bulloch v. City of Pascagoula, 574 So.2d 637 (Miss. 1990). {N/R}
     IL appellate court declines to hold employers liable because an internal investigation could have been conducted with greater skill. "An employer should have the right to directly confront its employee with allegations of unlawful activity. We will not require employers to finesse their way around direct allegations of criminal activity when confronting such employees in order to avoid making a possibly defamatory statement." Larson v. Decatur, 602 N.E.2d 864, 1992 Ill.App. Lexis 173 {N/R}
     Appellate court overturns $250,000 award to slandered police applicant. Allegation the applicant cheated was untrue, but made without malice. Dvorak v. O'Flynn, 808 S.W.2d 912 (Mo.App. 1991). [1992 FP 84]
     Sheriff, as a former employer, was privileged to state his opinion of the applicant to a prospective employer. Introini v. Richland County, 9 IER Cases (BNA) 1149 (D.S.C. 1993). [1994 FP 163]
     Terminated officer could not sue for reputational injuries because stigmatizing information was put in his employment file. Even if untrue, prior employer actually must disclose derogatory accusations before a compensable injury occurs. Johnson v. Martin, 943 F.2d 15 (7th Cir. 1991). » See also: Bishop v. Wood, 426 U.S. 341, 96 S.Ct. 2074 (1976); Ratliff v. City of Milwaukee, 795 F.2d 612 (7th Cir. 1986). Brandt v. Bd. of Co-op Educ. Serv., 820 F.2d 41 (2nd Cir. 1987) holds to the contrary. [1992 FP 52]
     Missouri police officer wins $2.25 million default judgment against the Klan over false allegations of misconduct. Robinson v. Ku Klux Klan, Greene Co. MO Cir. Ct. (7/18/91), as reported in the Springfield News-Leader.
     Ex-officer who killed UT sniper has sued TBS to stop reruns of a movie that depicts him as a coward; $14 million sought in damages. McCoy v. Turner Broadcasting Systems, Inc. U.S. Dist. Ct. (W.D. Tex. 11/28/90).
     Jury awards $210,000 in punitive damages against former employees who defamed two co-workers by allegations of unlawful conduct. Cincinnati Bell v. Gates, Cm. Pls. Hamilton Co. #A-8900494 (2/12/90).
     Training academy officials hit with $150,000 in punitive damages, plus $100,000 in compensatory damages, for slander of test candidate; defense unable to prove cheating allegation. [Steve] Dvorak v. Board of Police Cmsnrs. et al, Circuit Ct. of City of St. Louis (3/16/90).
     Councilman who publicly called chief a "dumb son-of-a-bitch" and "incompetent" did not commit a slander. Finck v. City of Tea, 443 N.W.2d 632 (S.D. 1989).
     Suit against official for defamation fails, when his questions and remarks were related to legitimate personnel matters. Robinson v. Egnor, 699 F.Supp. 1207 (E.D. Va. 1988).
     Qualified immunity privilege fails; officer awarded $10,000 for emotional distress, when defamed at a public meeting. English Jr. v. Smith Jr., Hampshire County, MA, Superior Court #84-016, 21 Pers. Inj. Verdict Rev. 4 (July, 1988).
     Chief could not sue town council or consultant for publication of a report critical of his leadership. Baumblatt v. Battalia, 520 N.Y.S.2d 471 (A.D. 1987).
     A city manager's untrue and defamatory statements, leading to the termination of a fire chief, cannot form the basis of a lawsuit; jury award of $74,000 set aside by appellate court. Town of South Padre Island v. Jacobs, 736 S.W.2d 134 (Reh., Tex.App. 1987).
     City could not be sued for libel in connection with employee's discharge. City of Dallas v. Moreau, 718 S.W.2d 776 (Tex.App. 1986).
     Jury awards $675,000 compensatory damages against city and chief, plus $50,000 punitive against chief for injuring reputations of subordinates. Giffin and King v. Ortega and City of Phoenix, Maricopa Co. Sup'r Ct. (5/2/86).
     No liability for truthfully answering news media's questions concerning termination of public employee. Karr v. Townsend, 606 F.Supp. 1121 (W.D. Ark. 1985).
     Sheriff not liable for defamation in suit by ex-deputy where sheriff did not disclose reasons for termination. Karr v. Townsend, 606 F.Supp. 1121 (W.D. Ark. 1985).
     Jury awards $150,000 for emotional distress and $100,000 punitive damages against sheriff who "defamed" a deputy; appellate court reduced the awards. Nellis v. Miller, 477 N.Y.S.2d 72 (A.D. 1984); Keller v. City of Reno, 587 F.Supp. 21 (D. Nev. 1984).
     Former employer could freely discuss applicant's work record with prospective employer; slander suit thrown out. City of Miami v. Wardlow, 403 So.2d 414 (Fla. 1981).
     Police officer has the same, but not a greater right, to bring a lawsuit against a citizen for reputational injuries. Mesa v. Rodriguez, 357 So.2d 711, 1978 Fla. Lexis 4767. {N/R}
     City held liable for defaming fired police chief; damages to be awarded. Owen v. City of Independence, Missouri, 560 F.2d 925 (8th Cir. 1977).

     See also: Employer References-Defamation & Other Claims; Civil Liability; Free Speech; Wrongful Discharge.

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