Krile v. Lawyer
Annotate this CaseRobyn Krile appealed a judgment dismissing her defamation claims against Julie Lawyer. In 2017, Assistant State’s Attorney Julie Lawyer received an anonymous letter concerning a Bismarck police officer’s destruction of evidence. During Lawyer’s investigation, she reviewed the file of Sergeant Robyn Krile and concluded Krile had made false statements as a Bismarck police officer. Lawyer sent a letter (“Giglio letter”) to Bismarck Police Chief Dan Donlin summarizing her investigation into Krile’s file and stating her belief that Krile had made false statements as a Bismarck police officer. Lawyer informed Chief Donlin that such information would have to be disclosed to the defense in cases in which Krile was involved pursuant to Giglio and, as a result, the Burleigh County State’s Attorney’s Office would no longer use Krile as a witness in its cases. The Bismarck Police Department terminated Krile’s employment because the Burleigh County State’s Attorney’s Office was no longer willing to use Krile as a witness. Krile filed a complaint with the Department of Labor and Human Rights claiming the Bismarck Police Department discriminated against her based on race and sex. As part of the Department of Labor’s investigation, the Bismarck Police Department submitted two affidavits of Lawyer in which she explained the circumstances and her reasoning for issuing the Giglio letter. The Department of Labor concluded the Bismarck Police Department did not unlawfully discriminate against Krile. In March 2019, Krile sued Lawyer in her official and individual capacity for defamation. The complaint alleged Lawyer defamed Krile by publishing the Giglio letter to the Bismarck Police Department, specifically Chief Donlin, and by publishing her affidavits to the Department of Labor in the course of its investigation. The complaint also alleged Lawyer defamed Krile by publishing the Giglio letter to the Peace Officer Standards and Training (POST) Board and by publishing the Giglio letter and related information to Krile’s prospective employers. Appealing the district court's judgment, Krile argued the district court erred by failing to consider all of the materials the parties submitted and thereby treat the motion to dismiss as a motion for summary judgment. She also argued the court erred in dismissing her defamation claims. The North Dakota Supreme Court affirmed, concluding Krile failed to plead a valid claim for defamation.
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