absolute litigation privilege (Delaware) · Go Syfert
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absolute litigation privilege in Delaware

9 Delaware opinions name it 3 courts 2011–2026 4 in the last five years

The cases below were cited by Delaware courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Barker v. Huanggreen
del · 1992 · cited in 4 Delaware opinions naming this issue, 2011–2024
2 sentences

2023The complaint was dismissed. 99 Barker v. Huang, 610 A.2d 1341, 1345 (Del. 1992). 100 Id. at 1349 . 101 See, e.g., Hawkins v. Harris, 661 A.2d 284, 288 (N.J. 1995) (recognizing that the absolute litigation privilege “does not protect against professional discipline for an attorney’s unethical conduct”); Ruberton v. Gabage, 654 A.2d 1002, 1007 (N.J.

2023The complaint was dismissed. 99 Barker v. Huang, 610 A.2d 1341, 1345 (Del. 1992). 100 Id. at 1349 . 101 See, e.g., Hawkins v. Harris, 661 A.2d 284, 288 (N.J. 1995) (recognizing that the absolute litigation privilege “does not protect against professional discipline for an attorney’s unethical conduct”); Ruberton v. Gabage, 654 A.2d 1002, 1007 (N.J.

44
Short v. News-Journal Companygreen
del · 1965 · cited in 2 Delaware opinions naming this issue, 2019–2020
2 sentences

2020Ch. 2019) (quoting Short v. News-Journal Co., 212 A.2d 718, 720 (Del. 1965)). 161 Barker v. Haung, 610 A.2d at 1345 (quoting Nix v. Sawyer, 466 A.2d 407, 411 (Del.

2019Mgmt., 22 A.3d at 711–712. 143 Short v. News-Journal Co., 212 A.2d 718, 720 (Del. 1965).

22
Mission Beverage Co. v. Pabst Brewing Co.green
calctapp5d · 2017 · cited in 1 Delaware opinions naming this issue, 2026–2026
1 sentence

2026But prelitigation communications “do not qualify as a protected activity if future litigation is not anticipated, and is therefore only a ‘possibility’—and this is true even if the communication is a necessary prerequisite to any future litigation.” Mission Beverage Co. v. Pabst Brewing Co., LLC, 223 Cal. Rptr. 3d 547, 559 (Cal. Ct. App. 2017).

11
Tatro v. Eshamgreen
delsuperct · 1975 · cited in 1 Delaware opinions naming this issue, 2024–2024
1 sentence

2024However, many jurisdictions ‘have recognized the utility in extending the privilege to cover communications made in advance of 30 Barker v. Huang, 610 A.2d 1341, 1344 (Del. 1992) 1344. 31 Tatro v. Esham, 335 A.2d 623, 625-26 (Del.

11
Hawkins v. Harrisgreen
nj · 1995 · cited in 1 Delaware opinions naming this issue, 2023–2023
1 sentence

2023The complaint was dismissed. 99 Barker v. Huang, 610 A.2d 1341, 1345 (Del. 1992). 100 Id. at 1349 . 101 See, e.g., Hawkins v. Harris, 661 A.2d 284, 288 (N.J. 1995) (recognizing that the absolute litigation privilege “does not protect against professional discipline for an attorney’s unethical conduct”); Ruberton v. Gabage, 654 A.2d 1002, 1007 (N.J.

11
Ruberton v. Gabagegreen
njsuperctappdiv · 1995 · cited in 1 Delaware opinions naming this issue, 2023–2023
1 sentence

2023The complaint was dismissed. 99 Barker v. Huang, 610 A.2d 1341, 1345 (Del. 1992). 100 Id. at 1349 . 101 See, e.g., Hawkins v. Harris, 661 A.2d 284, 288 (N.J. 1995) (recognizing that the absolute litigation privilege “does not protect against professional discipline for an attorney’s unethical conduct”); Ruberton v. Gabage, 654 A.2d 1002, 1007 (N.J.

11
NACCO INDUSTRIES, INC. v. Applica Inc.green
delch · 2009 · cited in 1 Delaware opinions naming this issue, 2022–2022
1 sentence

2022That is, if a breaching party can prevent its counterparty, via injunction, from making “disparaging” statements in litigation alleging the breach, then the counterparty would be unable to enforce the contract 82 NACCO Indus., Inc. v. Applica Inc., 997 A.2d 1, 35 (Del.

11
Savor, Inc. v. FMR Corp.green
del · 2002 · cited in 1 Delaware opinions naming this issue, 2022–2022
1 sentence

2022Mortg., 27 A.3d at 536 (citing Savor, Inc. v. FMR Corp., 812 A.2d 894, 895 (Del. 2002)). 60 Unbound Partners Ltd.

11
Nix v. Sawyergreen
delsuperct · 1983 · cited in 1 Delaware opinions naming this issue, 2020–2020
1 sentence

2020Ch. 2019) (quoting Short v. News-Journal Co., 212 A.2d 718, 720 (Del. 1965)). 161 Barker v. Haung, 610 A.2d at 1345 (quoting Nix v. Sawyer, 466 A.2d 407, 411 (Del.

11
Rain v. Rolls-Royce Corp.green
ca7 · 2010 · cited in 1 Delaware opinions naming this issue, 2019–2019
1 sentence

2019Can a party disparaged in litigation seek its damages under a contractual non-disparagement clause, even though a tort action on the same facts is barred for public policy reasons? 157 Fortunately for me, this 156 Answering Br., at 16. 157 Other states have considered the question of whether a claim for breach of contract can be barred by the absolute litigation privilege, and “[c]ourts in a number of jurisdictions have concluded that the absolute litigation privilege is applicable to breach of contract actions, at least where immunity from liability is consistent with the purpose of the privi

11
Klein v. Sunbeam Corp.green
del · 1952 · cited in 1 Delaware opinions naming this issue, 2019–2019
1 sentence

2019See, e.g., Klein v. Sunbeam Corp., 94 A.2d 385, 392 (Del. 1952) (“In the law of libel, privileged communications are divided into two classes, those absolutely privileged and those conditionally privileged.

11
Patrick D. Kelly v. Marc Goldengreen
ca8 · 2004 · cited in 1 Delaware opinions naming this issue, 2019–2019
2 sentences

2019For example, in Missouri the absolute litigation privilege is “based on the policy favoring freedom of expression and the desire not to inhibit parties from detailing and advocating their claims in court and is absolute, regardless of motive.” Kelly v. Golden, 352 F.3d 344, 350 (8th Cir. 2003).

2019For example, in Missouri the absolute litigation privilege is “based on the policy favoring freedom of expression and the desire not to inhibit parties from detailing and advocating their claims in court and is absolute, regardless of motive.” Kelly v. Golden, 352 F.3d 344, 350 (8th Cir. 2003).

11
Robertson v. Industrial Insurance Companygreen
fla · 1954 · cited in 1 Delaware opinions naming this issue, 2017–2017
2 sentences

2017Co., 75 So. 2d 198, 200 (Fla. 1954)). 12 Id. at 16. 7 asserts that, assuming Delaware law applies, limiting the absolute litigation privilege would defeat the purpose of the privilege.13 B.

2017Ct. App. 2014). 45 75 So. 2d 198, 200 (Fla. 1954). 46 Id. 47 Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins.

11
Nicholas A. James v. Daniel K. Leigh, and Kenny Leigh, P.A.green
fladistctapp · 2014 · cited in 1 Delaware opinions naming this issue, 2017–2017
1 sentence

2017Here, Tote meets that requirement, and the absolute litigation privilege applies. 44 James v. Leigh, 145 So. 3d 1006, 1008 (Fla. Dist.

11
Gilbert v. Peoplegreen
· 1845 · cited in 1 Delaware opinions naming this issue, 2011–2011
1 sentence

2011For instance, in the mid-nineteenth century New York case Gilbert v. People, the defendant was charged with trespass for "entering the close of the plaintiffs and taking and killing divers sheep, and for other alleged injuries to sheep, wool, sheepskins and mutton.” Gilbert v. People, 1 Denio 41, 44 (N.Y.Sup.Ct.1845).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Delaware. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Central Mortgage Co. v. Morgan Stanley Mortgage Capital Holdings LLC green
del · 2011
1 sentence

2022Mortg., 27 A.3d at 536 (citing Savor, Inc. v. FMR Corp., 812 A.2d 894, 895 (Del. 2002)). 60 Unbound Partners Ltd.

12022–2022
Hoover v. Van Stone green
ded · 1982
1 sentence

2019Oct. 31, 2018) (applying the absolute litigation privilege to statements made prior to judicial proceedings “so long as the statements were made in an effort to address the alleged grievance between the parties”). 141 Barker, 610 A.2d at 1345 (quoting Hoover, 540 F.Supp. at 1122 ). 30 to testify freely and counsel to argue zealously, and limiting the proliferation of follow-on lawsuits.”142 The absolute litigation privilege “affords a complete defense [to the tort of defamation] irrespective of accuracy or malice.” 143 That is because “the interest in encouraging a litigant’s unqualified cando

12019–2019
Paige Capital Management, LLC v. Lerner Master Fund, LLC green
delch · 2011
2 sentences

2019Mgmt., 22 A.3d at 722–23 (assuming, without deciding, that the absolute litigation privilege may extend to pre-litigation communications); BRP Hold Ox.

2019Mgmt., 22 A.3d at 711–712. 143 Short v. News-Journal Co., 212 A.2d 718, 720 (Del. 1965).

12019–2019
Flanagan v. Blumenthal green
conn · 2003
1 sentence

2017June 5, 2014) (“In denying the appellant‟s motion to dismiss based on the absolute litigation privilege, the Superior Court did not finally determine a claim of right of the appellant.”); Manley v. Marisco, 876 N.E. 2d 910 , 911 (Ohio 2007) (finding that an order denying a motion to dismiss for failure to comply with the affidavit- of-merit requirement under the Ohio Civil Rules does not qualify for immediate appellate review); Flanagan v. Blumenthal, 828 A.2d 572 , 573 n.4 (Conn. 2003) (internal quotations and citations omitted) (“The general rule is that the denial of a motion dismiss is an

12017–2017

Where else courts name it

CA 36 (1990–2024) IL 21 (2014–2026) DE 9 (2011–2026) MD 7 (2010–2024) NY 7 (2020–2025) HI 6 (2003–2023) NV 6 (2017–2021) MA 4 (2001–2011) FL 4 (2014–2024) CO 2 (2026–2026) NJ 2 (2017–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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