Cole v. Chandler
2000 ME 104 · Supreme Judicial Court of Maine · 2000
Facts
Curtis Cole was the controller and head of the financial department at Mead Corporation's Rumford paper mill from April to October 1997, supervising Brenda Chandler and Pola Buckley. In mid-October 1997, Chandler's husband reported to human resources that Cole had told a sexually explicit joke to Chandler, which upset her. An HR investigation ensued, during which Chandler reported the joke and Cole's suggestion that male and female seminar attendees share rooms. Buckley reported several incidents, including Cole yelling a suggestive remark, asking her for a drink, asking for a back rub, and telling an inappropriate sexual joke. After being interviewed by HR on October 24, Cole was suspended, and his employment was terminated on October 28, 1997, based on these reported events.
Procedural history
Plaintiff Curtis Cole filed separate complaints against Brenda Chandler and Pola Buckley, which were later consolidated. Cole then filed an amended complaint, adding Mead Corporation as a defendant. The Superior Court granted summary judgment for Chandler and Buckley, finding them immune under the Workers’ Compensation Act, and also granted summary judgment for Mead Corporation, finding it protected by immunity. Cole appealed both judgments to this court.
Issue
Did the lower court err in granting summary judgment to Mead Corporation, Chandler, and Buckley by finding them immune from Cole's claims for defamation, invasion of privacy, interference with economic relations, and intentional infliction of emotional distress? Specifically, was Mead protected by a conditional privilege against compelled self-publication defamation, and were Chandler and Buckley immune under the Workers' Compensation Act exclusivity provision for all claims?
Holding
The court affirmed summary judgment for Mead Corporation and Brenda Chandler. It affirmed summary judgment for Pola Buckley regarding claims for intentional infliction of emotional distress, invasion of privacy, punitive damages, and personal injury aspects of defamation and interference with economic relations. However, the court vacated summary judgment for Buckley regarding non-personal injury claims of defamation and interference with economic relations, finding a genuine issue of material fact regarding abuse of privilege.
Rule
A conditional privilege protects employers and employees from defamation claims in employment contexts, such as termination, unless the privilege is abused by making statements with malice (knowing falsity, reckless disregard for truth, or spite/ill will). The Workers' Compensation Act's exclusivity provision bars civil actions for "personal injuries" (mental or physical) sustained by an employee arising out of and in the course of employment, even for intentional torts, but does not preclude recovery for economic or reputational injuries. For an invasion of privacy claim based on false light, "publicity" requires communication to the public at large or so many persons that it is substantially certain to become public knowledge.
Read the full opinion on CourtListener
Case brief last reviewed . Prepared by CaseReader from the published opinion.