Desjardins v. Willard, No. 14-1786 (1st Cir. 2015)
Annotate this CasePlaintiff, a town official for the town of Raymond, claimed that Michael Reynolds, a fellow town official, told the sheriff’s department that Plaintiff had driven while intoxicated, that the reports were false, and the false statements damaged his reputation. Plaintiff brought suit in state superior court, alleging state law claims for defamation and false light invasion of privacy, as well as federal claims under 42 U.S.C. 1983. The case was removed to federal court on the basis of the federal claims. The district court dismissed the federal claims and proceeded to resolve the state law claims. The First Circuit (1) affirmed the dismissal of the federal claim; and (2) vacated the dismissal of Plaintiff’s state law claims as to Reynolds and remanded the claims to state court, holding the state law claims involved resolution of a potential conflict between Maine’s Anti-SLAPP statute and Maine’s Constitution, a conflict that “is best resolved by the Maine courts.”
The court issued a subsequent related opinion or order on February 2, 2015.
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