Summary
The Massachusetts Supreme Judicial Court considered defamation claims brought by Saundra R. Edwards against former Governor Deval Patrick based on statements about her removal as chair of the Sex Offender Registry Board. The court held that Edwards had not pleaded sufficient facts to establish actual malice, and therefore the defamation claims should have been dismissed. The court did not decide whether a governor has an absolute privilege for statements made in the performance of official duties.
Topics
Practice areas
Questions Presented
- Whether Edwards's amended complaint pleaded sufficient facts to overcome the qualified or conditional privilege protecting Patrick's official statements to the media by establishing actual malice.
- Whether the Supreme Judicial Court should recognize an absolute privilege for a governor's statements made in the performance of official duties.
Holdings
- The amended complaint did not allege facts sufficient to establish that Patrick knew his statements were false or acted with reckless disregard for their truth or falsity. Edwards's defamation claims therefore failed to overcome the qualified or conditional privilege applicable to Patrick's statements and should have been dismissed.
- The court did not decide whether a governor or other high-ranking state official enjoys an absolute privilege for statements made in the performance of official duties.
Key quotations
“Reckless disregard requires more than negligence; a plaintiff must prove that the individual making the alleged defamatory statement "entertained serious doubts as to the truth" of the statement.” (slip op. at 17-18)
“Evidence of ill will or spite is insufficient, standing alone, to establish actual malice.” (slip op. at 23)
“That Patrick might have harbored ill will toward Edwards for "nearly destroy[ing]" the lives of some members of his family does not substitute for proof of actual malice.” (slip op. at 23-24)
Factual background
Saundra Edwards served as chair of the Massachusetts Sex Offender Registry Board, a position held at the governor's pleasure, until Governor Deval Patrick replaced her in September 2014. After her removal, Patrick told the media that Edwards had inappropriately pressured a SORB hearing officer to change the outcome of a sex-offender-classification matter involving Patrick's brother-in-law. Edwards alleged that the statements were defamatory and that Patrick made them with actual malice, relying on statements by an administration official, the contents of a whistleblower lawsuit, and Patrick's alleged personal hostility toward her.
Procedural history
Edwards filed a Superior Court action against the Commonwealth for wrongful termination and against Patrick individually for defamation based on statements concerning her removal as chair of the Sex Offender Registry Board. After Edwards amended her complaint to add a second defamation claim, Patrick moved to dismiss on absolute- and qualified-privilege grounds. The Superior Court denied the motion, and the Supreme Judicial Court granted Patrick's application for direct appellate review.