Smith v. Idexx Lab., Inc.

CourtSuperior Court of Maine
DecidedJanuary 11, 2000
DocketCUMcv-99-493
StatusUnpublished

This text of Smith v. Idexx Lab., Inc. (Smith v. Idexx Lab., Inc.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Idexx Lab., Inc., (Me. Super. Ct. 2000).

Opinion

STATE OF MAINE.) 00) SUPERIOR COURT CUMBERLAND, ss. DA pT EGE CIVIL DOCKET NO. CV-99-493

{4 3 20 PA ‘Od [CEd-auUN- Ji Ji] C2 L269

KATHI SMITH, ) Plaintiff, ) ) v. )

) DECISION AND ORDER IDEXX LABORATORIES, INC., ) and ) IDEXX DISTRIBUTION CORP., ) Defendants. )

FACTUAL BACKGROUND

Plaintiff Kathi Smith (“Smith”) was employed by Defendants Idexx (“Idexx”) from May 1997 to December 31, 1998. During the evening of October 4, 1998, Smith was missing some forms that she needed the next day for a training seminar. Plaintiff’s Statement of Material Facts (“PSMF”) 74; Amended Complaint, 731. She went to work to look for them. Id. While searching, she discovered a file with her name on it, opened it, and found some disturbing notes about her written by a Caroline Bickford. PSMF 45. The file was not in a locked cabinet nor marked “confidential.” PSMF 94. Smith told her supervisor and one other co-worker about the discovery. PSMF 96. Smith was upset at the access any employee could have had to the file, and later found out that her performance review was available on Idexx’s “R drive.” PSMF { 7-8.

While Smith was at Idexx, she was alleged to be involved as a perpetrator of harassment, and Idexx investigated that complaint. Idexx never told Smith who filed the complaint. PSMF 414. Smith was not disciplined after Idexx’s

investigation, because it exonerated her. Defendants’ Statement of Material Facts (“DSMF”) 411. However, Plaintiff asserts that Idexx informed her that if another complaint were filed against her, Smith would be terminated. PSMF 413. Shortly after Smith left Idexx’s employment, Conan Deady (“Deady”), general counsel at Idexx, was informed that while the investigation was pending against her, Smith had broken into the files of her supervisor and that she had not been disciplined for doing so. DSMF 95.

In December of 1998, Idexx decided to shut down the division in which Smith worked, and offered all employees a severance package in exchange for releasing all claims. DSMF 96, PSMF 49. Smith did not take the package, but rather hired attorney Beth George (“George”) to write a demand letter threatening legal claims against Idexx, including violation of whistleblower laws, intentional infliction of emotional distress and sexual harassment. Id.

Deady responded to this threatened litigation by writing back to George, and copied the letter to Donalee Santoro and Mason Pratt, Idexx’s Manager of Employee Relations and outside counsel, respectively. DSMF 779-10. The last sentence of the letter states “you may wish to know that Ms. Smith broke into the files of her

supervisor in an attempt to identify her accuser, a matter for which she was not

disciplined!.” DSMF 99. “Her accuser” is a reference to the co-worker that made the

1 This statement by Deady is the only one in her original complaint (August 25, 1999) that plaintiff alleged to be defamatory. Defendants submitted their Motion for Summary Judgment on October 14, 1999. Subsequently, Plaintiff filed an Amended Complaint on October 28, 1999, which alleges further defamatory statements.

Plaintiff alleged that Defendants refused to answer two document requests regarding the Deady statement, namely numbers 26 and 29. Request #26 seeks any document providing a basis for the Deady statement. See Attachment “A” to Plaintiff’s Opposition Brief. This request is not relevant to Plaintiff’s defamation claim based upon the Deady statement, because Defendants have not claimed

2 harassment complaint. DSMF 2-4.

Smith then filed a complaint in this Court alleging failure to pay wages (Count 1), violation of the minimum wage laws (Count II), and defamation (Count III). Idexx moved for summary judgment on Count III.

DISCUSSION

The Law Court recognizes an absolute privilege for statements made during the course of a judicial proceeding. See Dineen y. Daughan, 381 A.2d 663, 664-65 (Me. 1978); Restatement (Second) of Torts §§ 586”, 587 (1977). The privilege’s potential to become a license to defame is tempered by its limitations. The

statements must be relevant or pertinent to the proceedings. See Dineen, 381 A.2d

at 665. Additionally, the privilege can be lost by “unnecessary or unreasonable

truth asa defense. Request #29 seeks any documents from Deady communicating that Smith broke into the files of her supervisor to discover the identity of her accuser. See Attachment “A” to Plaintiff's Opposition Brief. Defendants responded that there are no documents, other than the Deady letter itself, that are responsive to Requests 27-29. See Attachment “A” to Defendants’ Reply Brief.

Plaintiff's attorney filed a motion, pursuant to M.R. Civ.P. 56(f), requesting that the court allow her to pursue further avenues of discovery on the newly alleged statements. At the hearing on this motion, it became clear that the additional discovery sought does not address her defamation claim based on the Deady statement. See Attachment A to Defendants’ Reply Brief.

As to additional statements alleged in her Amended Complaint, however, the plaintiff should be allowed to conduct the requested discovery. Accordingly, this motion addresses only the statement alleged in the original complaint (Deady’s statement in response to the George letter). Once discovery is completed, Defendants are not precluded by this Order from seeking summary judgment as to the additional statements in the Amended Complaint.

2 Section 586 of the Restatement (Second) of Torts states:

An attorney at law is absolutely privileged to publish defamatory matter concerning another in communications preliminary to a proposed judicial proceeding, or in the institution of, or during the course and as a part of, a judicial proceeding in which he participates as counsel, if it has some relation to the proceeding. publication beyond the scope of the privileged circumstances.” Vahlsing Christina Corp. v. Stanley, 487 A.2d 264, 267 (Me. 1985).

The Restatement’s version of the absolute privilege includes statements made “preliminary to a proposed judicial proceeding.” See §586. While the Law Court has explicitly recognized statements made during a judicial proceeding to be privileged, it has not had occasion to recognize a privilege for statements made prior

_ to the instituting of a judicial proceeding. However, the Law Court has generally

recognized the privileges in the Restatement §§582-598A. See Saunders v. VanPelt,

497 A.2d 1121, 1125 (Me. 1985), Creamer v. Danks, 700 F.Supp. 1169, 1172 n.4 (D. Me. 1988), aff’d 863 F.2d 1037 (1st Cir. 1988) (noting the Law Court’s adoption of the relevant Restatement sections). Furthermore, the policy reasons given by the Law Court justifying an absolute privilege for statements made within a judicial proceeding align with those given by other courts and by the Restatement justifying an absolute privilege for statements made prior to a judicial proceeding. See

Dineen, 381 A.2d at 664-665 (“just as a witness needs the freedom to be able to

answer questions posed, free of any concern except the truth as he believes it to be, an attorney must be free to assert relevant statements to pursue fully the interests of

his client”); see also Tanguay v. Asen, 722 A.2d 49, 50 (Me. 1998) (recognizing “at

least a qualified privilege of counsel to inquire and develop evidence relevant to the proceeding”); Restatement (Second) of Torts § 586, comment a ("The privilege stated in this Section is based upon a public policy of securing to attorneys as officers of the

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Related

Tanguay v. Asen
1998 ME 277 (Supreme Judicial Court of Maine, 1998)
Creamer v. Danks
700 F. Supp. 1169 (D. Maine, 1988)
Saunders v. VanPelt
497 A.2d 1121 (Supreme Judicial Court of Maine, 1985)
CRIBERG v. Raymond
345 N.E.2d 882 (Massachusetts Supreme Judicial Court, 1976)
Dineen v. Daughan
381 A.2d 663 (Supreme Judicial Court of Maine, 1978)
Vahlsing Christina Corp. v. Stanley
487 A.2d 264 (Supreme Judicial Court of Maine, 1985)

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