Hayhurst v. Timberlake

CourtDistrict Court, D. New Hampshire
DecidedJuly 8, 1996
DocketCV-94-199-SD
StatusPublished

This text of Hayhurst v. Timberlake (Hayhurst v. Timberlake) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hayhurst v. Timberlake, (D.N.H. 1996).

Opinion

Hayhurst v . Timberlake CV-94-199-SD 07/08/96 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Donald Hayhurst, N.M.D.

v. Civil N o . 94-199-SD

Robert Timberlake, et al

O R D E R

This diversity action concerns allegations of libel, slander, and conspiracy. By order dated May 1 5 , 1996, the court conditionally granted summary judgment for defendants, but granted plaintiff leave to move to amend his complaint. Presently before the court is plaintiff's motion to reconsider said order, brought pursuant to Rule 59(e), Fed. R. Civ. P. The background of this case was outlined by the court in the previous order, and such recitation of facts will not be repeated here.

Discussion

1. Publication of the AANP Quarterly Article to New Hampshire

Legislators

In its previous order, the court ruled that despite the

allegations in the complaint, plaintiff had not produced

sufficient evidence to support his contention that defendants had published an article appearing in defendants' publication, The AANP Quarterly, to two state representatives. The court's ruling was based on affidavits of both legislators stating that they did not recall receiving such material from defendant Robert Timberlake. The court also noted that it was not persuaded by plaintiff's argument in response, which was merely to point out that defendants had provided other allegedly defamatory material to the legislators.

In his motion to reconsider, plaintiff argues that he has now produced sufficient circumstantial evidence of the publication to the two legislators to avoid summary judgment. First, plaintiff notes that he attached to his objection to defendants' summary judgment motion an affidavit of Patricia DeSilvio, N.D., in which she claims to have picked up a package of materials from the "state" regarding the proposed legislation concerning licensure of naturopaths. He now asserts, without supporting documentation, that DeSilvio will testify at trial that the material was obtained from Representative Wheeler's office and that it contained the accused AANP article. He further states that DeSilvio will testify at trial that she also obtained the article from the House Committee Research Office.

Rule 56(e), Fed. R. Civ. P., provides in relevant part:

When a motion for summary judgment is made and supported as provided in this rule, an adverse

2 party may not rest upon the mere allegations or denials of the adverse party's pleading, but the adverse party's response, by affidavits or as otherwise provided in this rule, must set forth specific facts showing that there is a genuine issue for trial.

As plaintiff's circumstantial evidence of publication rests

primarily upon his unsupported assertions of what DeSilvio "will

testify at trial," and as plaintiff has not submitted specific

facts via affidavits or otherwise, the court will not alter its

original ruling.

Moreover, even had the plaintiff provided circumstantial

evidence that Timberlake sent a copy of the A A N P article to

Representative Wheeler's office, plaintiff still has not

fulfilled the requirements of establishing publication. To

satisfy its burden of proof, plaintiff must not only show that

defendants made the defamatory material available to a third

person, but also that the third person understood its

significance. See RESTATEMENT (SECOND) OF TORTS § 613, cmt. d

(1976). As plaintiff has provided no evidence to contradict the

affidavit of Representative Wheeler, in which she states that she

does not even recall seeing the A A N P article, much less reading

i t , see Affidavit of Katherine Wheeler ¶ 8 (attached to

Plaintiff's Motion to Reconsider), plaintiff has not satisfied

his burden of showing Representative Wheeler understood the

significance of the materials.

3 2. Publication of Deposition Testimony and the Sheriff's Report

to the New Hampshire Legislators

In his motion for reconsideration, plaintiff argues that the

court erred by ruling that defendants were protected by a

conditional privilege when Timberlake published excerpts from

deposition testimony taken in another trial, and a sheriff's report, to members of the state legislature. Timberlake

submitted the materials in response to a request by members of

the legislature for information about Hayhurst's credentials. At

the time, the legislature was considering a bill that would

impose licensing requirements on the practice of naturopathy, and

Timberlake had testified before a legislative committee regarding

the bill. The court need not address plaintiff's contentions,

however, because the ruling to dismiss this portion of

plaintiff's claim is sustainable on the alternate ground that

such communications are protected by an absolute privilege.1

Absolute privileges are reserved for those situations where

"the public interest is so vital and apparent that it mandates

complete freedom of expression without inquiry into a defendant's

motives." Supry v . Bolduc, 112 N . H . 2 7 4 , 276, 293 A.2d 7 6 7 , 769

(1972) (citing W . PAGE KEETON, ET A L . , PROSSER AND KEETON ON THE LAW OF

1 In its previous order, the court deferred ruling on the issue of absolute immunity.

4 TORTS § 1 1 4 , at 776, et seq. (4th ed. 1971)). It is settled in

New Hampshire that statements made in the course of judicial

proceedings constitute one such situation, provided that they are

pertinent to the subject of the proceeding. See McGranahan v .

Dahar, 119 N . H . 7 5 8 , 762-63, 408 A.2d 1 2 1 , 123-24 (1979) (citing

cases and PROSSER AND KEETON, supra, § 1 1 4 , at 777-78). This is because the potential harm inflicted on the defamed individual is

"far outweighed by the need to encourage participants in

litigation, parties, attorneys, and witnesses, to speak freely in

the course of judicial proceedings." Id. at 763, 408 A.2d at

124. The courts of many states recognize that the common law

rule of absolute immunity for statements made in the course of

judicial proceedings applies with equal force to statements made

in the course of legislative proceedings. See, e.g. PROSSER AND

KEETON, supra, § 1 1 4 , at 820 (5th ed. 1984) (and cases cited);

Webster v . Sun Co., 731 F.2d 1 , 4 ( D . C . Cir. 1984), appealed

after remand, 790 F.2d 157 ( D . C . Cir. 1986); Yip v . Pagano, 606

F . Supp. 1566, 1570-73 (D.N.J. 1985), aff'd, 782 F.2d 1033 (3d

C i r . ) , cert. denied, 476 U . S . 1141 (1986); Bio/Basics Int'l v .

Ortho Pharmaceutical Corp., 545 F . Supp. 1106, 1114-15 ( S . D . N . Y .

1982); DeSantis v . Employees Passaic County Welfare Ass'n, 568

A.2d 565, 567 (N.J. Super. App. D i v . ) , cert. denied, 584 A.2d 231

(N.J. 1990); Jennings v . Cronin, 389 A.2d 1183, 1185 (Pa. Super.

5 C t . 1978). The general proposition is articulated in the

RESTATEMENT (SECOND) OF THE LAW OF TORTS § 590A: " A witness is

absolutely privileged to publish defamatory matter as part of a

legislative proceeding in which he is testifying or in

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