Zeigler v. Rater, No. 18-2150 (1st Cir. 2019)
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The First Circuit affirmed the district court's entry of summary judgment in favor of Defendant in this defamation case, holding that no reasonable jury could find that Defendant, a psychiatrist, abused the conditional privilege under which Defendant disseminated an allegedly libelous report to an employer about an employee's fitness to return to work after medical leave.
Plaintiff took medical leave from work due to stress purportedly caused by derogatory remarks about Plaintiff's age. The Human Resources department required Plaintiff to undergo a psychiatric evaluation to determine his fitness to return to work. Defendant issued a written report concluding that Plaintiff would be unfit to return to work for at least three months. Plaintiff filed this complaint arguing that the report contained at least two libelous statements. The district court entered summary judgment in favor of Defendant, concluding that the challenged statements were conditionally privileged and that there was insufficient evidence to show that Defendant abused the conditional privilege. The First Circuit affirmed, holding that the district court properly found Defendant's statements in the report conditionally privileged and that Plaintiff failed to establish sufficient evidence to show any abuse of that privilege.
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