Cited by

v. London, Sierra Madre Dev., Inc. v. Via Entrada Townhouses Ass’n, –53 (1973).

v. London, -19 (1984) (addressing reports about statements made in public proceedings).

Even if the statements in the January letter were false, “[t]he defense is absolute in that the speaker’s motive, purpose or reasonableness in uttering a false statement do not affect the defense.”

v. London, (quoting Prosser, Law of Torts (4th ed. 1971) § 114, p. 776 (footnote omitted))

v. London, ¶ 9 (App. 2020) (applying an absolute privilege to an injunction against harassment petition).

v. London, (citation omitted) (ruling lawyers immune from defamation suit because motive, purpose, and reasonableness do not affect immunity); ¶ 12 (App. 2007) (ruling judicial immunity protects a court employee who makes a discriminatory recommendation based on employee’s bias against

v. London, see also Rehberg v. Paulk, 566 U.S. 356, 369 (2012).

To qualify for the privilege, an allegedly defamatory publication “must relate to, bear on or be connected with the proceeding.”

Ct. App. 1962) (recognizing that an absolute privilege applies to statements made from the bench); (explaining that the absolute privilege generally applies to judicial proceedings and “protects judges, parties, lawyers, witnesses and jurors”).

.” Restatement (Second) of Torts (Restatement) § 611 (1977); (applying Restatement § 611).

e Privilege for Statements by Witnesses in Litigation ¶ 9 It is well established in Arizona that statements that would otherwise be actionable in defamation will “escape liability because the defendant is acting in furtherance of some interest of social importance, which is entitled to protection even at the expense of uncompensated harm to the plaintiffs reputation.” , (quoting Prosser, Law of Torts (4th Ed.1971) § 114, p. 776); , W. Tech., Inc. v. Sverdrup & Parcel, Inc.

But in light of the Arizona authority describing conditional privilege as a defense to a defamation action, see Green Acres Trust v. London, 141 Ariz. 609, 616, it would be premature to address privilege on appeal in the context of a pre-answer motion to dismiss.

In addition, “[w]hether a communication is privileged is a question of law for the court; we are not bound by the trial court’s conclusions of law, which we review de novo.” n.2, n.2 (App. 2006).

1000, 1001 (App. 2006), the assertedly defamatory statements were found, respectively, in complaints to the State Bar of Arizona and to the Board of Legal Document Preparers.5 ¶15 Here, however, Chilton did not sue CBD for the statements it had made to the USFS during the appeal process, but for the material subsequently published on CBD’s website.6 -15, -23 (1984) (no absolute immunity for statements by lawyers to reporter outside of judicial proceeding); Alarcon, 131 P.3d at 491-92 (“[A]bsolut

613 n. 1, , 621 n. 1 (1984).

As a defense to a defamation action, the Supreme Court of Arizona has recognized that certain statements that normally would be actionable will not be because the speaker is acting “ ‘in furtherance of some interest of social importance, which is entitled to protection even at the expense of uncompensated harm to the plaintiffs reputation.’ ” Green Acres Trust v. London, 141 * (quoting Prosser, Law of Torts § 114, p. 776 (4th ed.1971)).