defense of qualified privilege (Pennsylvania) · Go Syfert
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defense of qualified privilege in Pennsylvania

9 Pennsylvania opinions name it 4 courts 1938–2025 2 in the last five years

The cases below were cited by Pennsylvania 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 (5)

CaseFollowedCited
Wecht v. PG Publishing Co.green
pa · 1986 · cited in 2 Pennsylvania opinions naming this issue, 2018–2025
2 sentences

2025Co., 510 A.2d 769, 771 (Pa. Super. 1986).

2018Co., 510 A.2d 769, 771 (Pa. Super. 1986), appeal denied, 522 A.2d 559 (Pa. 1987) (citations omitted; emphases added).

22
Lorenzo Oliver v. Debra Roquetgreen
ca3 · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2025–2025
1 sentence

2025If Kattner now views the complaint as asserting a federal claim for damages under Section 1983 against him in his personal capacity, and wishes to assert the defense of qualified immunity, see Kattner’s Br. at 25-27, we note that Kattner does not appear to have raised that defense below, though qualified immunity might properly be raised after the preliminary objection stage, see Oliver v. Roquet, 858 F.3d 180, 188 (3d Cir. 2017).

11
Dempsky v. Doublegreen
pa · 1956 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
2 sentences

2007Dempsky v. Double, 386 Pa. 542, 547 , 126 A.2d 915, 917 (1956); Biggans v. Foglietta, 403 Pa. 510, 512 , 170 A.2d 345, 346 (1961) (if the court determines that the alleged defamatory publication is privileged and there is no intrinsic or extrinsic evidence of malice, the court has a duty to direct a nonsuit or give binding instructions for the defendant); Corabi, 441 Pa. at 452 , 273 A.2d at 909 ("[I]f the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated.").

2007Dempsky v. Double, 386 Pa. 542, 547 , 126 A.2d 915, 917 (1956); Biggans v. Foglietta, 403 Pa. 510, 512 , 170 A.2d 345, 346 (1961) (if the court determines that the alleged defamatory publication is privileged and there is no intrinsic or extrinsic evidence of malice, the court has a duty to direct a nonsuit or give binding instructions for the defendant); Corabi, 441 Pa. at 452 , 273 A.2d at 909 ("[I]f the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated.").

11
Biggans v. Fogliettagreen
pa · 1961 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
2 sentences

2007Dempsky v. Double, 386 Pa. 542, 547 , 126 A.2d 915, 917 (1956); Biggans v. Foglietta, 403 Pa. 510, 512 , 170 A.2d 345, 346 (1961) (if the court determines that the alleged defamatory publication is privileged and there is no intrinsic or extrinsic evidence of malice, the court has a duty to direct a nonsuit or give binding instructions for the defendant); Corabi, 441 Pa. at 452 , 273 A.2d at 909 ("[I]f the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated.").

2007Dempsky v. Double, 386 Pa. 542, 547 , 126 A.2d 915, 917 (1956); Biggans v. Foglietta, 403 Pa. 510, 512 , 170 A.2d 345, 346 (1961) (if the court determines that the alleged defamatory publication is privileged and there is no intrinsic or extrinsic evidence of malice, the court has a duty to direct a nonsuit or give binding instructions for the defendant); Corabi, 441 Pa. at 452 , 273 A.2d at 909 ("[I]f the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated.").

11
Corabi v. Curtis Publishing Co.green
pa · 1971 · cited in 1 Pennsylvania opinions naming this issue, 2007–2007
2 sentences

2007Dempsky v. Double, 386 Pa. 542, 547 , 126 A.2d 915, 917 (1956); Biggans v. Foglietta, 403 Pa. 510, 512 , 170 A.2d 345, 346 (1961) (if the court determines that the alleged defamatory publication is privileged and there is no intrinsic or extrinsic evidence of malice, the court has a duty to direct a nonsuit or give binding instructions for the defendant); Corabi, 441 Pa. at 452 , 273 A.2d at 909 ("[I]f the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated.").

2007Dempsky v. Double, 386 Pa. 542, 547 , 126 A.2d 915, 917 (1956); Biggans v. Foglietta, 403 Pa. 510, 512 , 170 A.2d 345, 346 (1961) (if the court determines that the alleged defamatory publication is privileged and there is no intrinsic or extrinsic evidence of malice, the court has a duty to direct a nonsuit or give binding instructions for the defendant); Corabi, 441 Pa. at 452 , 273 A.2d at 909 ("[I]f the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated.").

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (13)

CaseCitedYears
Burke v. Triangle Publications, Inc. green
pasuperct · 1973
2 sentences

1986Vitteck v. Washington Broadcasting Co., Inc., 256 Pa.Super. 427, 389 A.2d 1197 (1978); Burke v. Triangle Publications, Inc., 225 Pa.Super. 272, 302 A.2d 408 (1973).

1986Vitteck v. Washington Broadcasting Co., Inc., 256 Pa.Super. 427, 389 A.2d 1197 (1978); Burke v. Triangle Publications, Inc., 225 Pa.Super. 272, 302 A.2d 408 (1973).

11986–1986
Vitteck v. Washington Broadcasting Co. green
pasuperct · 1978
2 sentences

1986Vitteck v. Washington Broadcasting Co., Inc., 256 Pa.Super. 427, 389 A.2d 1197 (1978); Burke v. Triangle Publications, Inc., 225 Pa.Super. 272, 302 A.2d 408 (1973).

1986Vitteck v. Washington Broadcasting Co., Inc., 256 Pa.Super. 427, 389 A.2d 1197 (1978); Burke v. Triangle Publications, Inc., 225 Pa.Super. 272, 302 A.2d 408 (1973).

11986–1986
Greenberg v. Aetna Insurance green
pa · 1967
2 sentences

1973To support its position, the defendant-newspaper relies on Greenberg v. Aetna Insurance Co., 427 Pa. 511 , 235 A. 2d 576 (1967), cert. denied, 392 U.S. 907 (1968), in which the Supreme Court of Pennsylvania allowed a defense of privilege to be raised by preliminary objections.

1973To support its position, the defendant-newspaper relies on Greenberg v. Aetna Insurance Co., 427 Pa. 511 , 235 A. 2d 576 (1967), cert. denied, 392 U.S. 907 (1968), in which the Supreme Court of Pennsylvania allowed a defense of privilege to be raised by preliminary objections.

11973–1973
An Article of Device . . . Diapulse Manufacturing Corp. of America v. United States green
scotus · 1968
1 sentence

1973To support its position, the defendant-newspaper relies on Greenberg v. Aetna Insurance Co., 427 Pa. 511 , 235 A. 2d 576 (1967), cert. denied, 392 U.S. 907 (1968), in which the Supreme Court of Pennsylvania allowed a defense of privilege to be raised by preliminary objections.

11973–1973
Sciandra v. Lynett green
pa · 1963
1 sentence

1971Such malice is inferred, as a matter of law, when the “occasion of privilege” is shown to have been “abused” : 10 Sciandra v. Lynett, 409 Pa. 595 , 187 A. 2d *453 586 (1963).

11971–1971
Curtis Publishing Co. v. Butts green
scotus · 1967
2 sentences

1971When such is established, both the Act of August 21, 1953, supra, and the Restatement of Torts require that plaintiff prove the “abuse of [the] con *453 ditionally privileged occasion.” When such “abuse” is proved, “actual malice” is inferred as a matter of law, and the defense of qualified privilege is vitiated. 11 As to public figures, see Curtis Publishing Co. v. Butts, 388 U.S. 130 , 87 S. Ct. 1975 (1967), and Greenbelt Cooperative Publishing Ass’n v. Bresler, 398 U.S. 6 , 90 S. Ct 1537 (1970). 12 The United States Supreme Court eases are consistent with our interpretation.

1971When such is established, both the Act of August 21, 1953, supra, and the Restatement of Torts require that plaintiff prove the “abuse of [the] con *453 ditionally privileged occasion.” When such “abuse” is proved, “actual malice” is inferred as a matter of law, and the defense of qualified privilege is vitiated. 11 As to public figures, see Curtis Publishing Co. v. Butts, 388 U.S. 130 , 87 S. Ct. 1975 (1967), and Greenbelt Cooperative Publishing Ass’n v. Bresler, 398 U.S. 6 , 90 S. Ct 1537 (1970). 12 The United States Supreme Court eases are consistent with our interpretation.

11971–1971
Greenbelt Cooperative Publishing Assn., Inc. v. Bresler green
scotus · 1970
2 sentences

1971When such is established, both the Act of August 21, 1953, supra, and the Restatement of Torts require that plaintiff prove the “abuse of [the] con *453 ditionally privileged occasion.” When such “abuse” is proved, “actual malice” is inferred as a matter of law, and the defense of qualified privilege is vitiated. 11 As to public figures, see Curtis Publishing Co. v. Butts, 388 U.S. 130 , 87 S. Ct. 1975 (1967), and Greenbelt Cooperative Publishing Ass’n v. Bresler, 398 U.S. 6 , 90 S. Ct 1537 (1970). 12 The United States Supreme Court eases are consistent with our interpretation.

1971When such is established, both the Act of August 21, 1953, supra, and the Restatement of Torts require that plaintiff prove the “abuse of [the] con *453 ditionally privileged occasion.” When such “abuse” is proved, “actual malice” is inferred as a matter of law, and the defense of qualified privilege is vitiated. 11 As to public figures, see Curtis Publishing Co. v. Butts, 388 U.S. 130 , 87 S. Ct. 1975 (1967), and Greenbelt Cooperative Publishing Ass’n v. Bresler, 398 U.S. 6 , 90 S. Ct 1537 (1970). 12 The United States Supreme Court eases are consistent with our interpretation.

11971–1971
Abdallah v. United States green
scotus · 1945
1 sentence

1971This is so because, by definition, the communication is published in furtherance of some overriding .social interest and is therefore not “wrongful.” Nevertheless, if the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated: Bausewine v. Norristown Herald, 351 Pa. 634 , 41 A. 2d 736 , cert. denied, 326 U.S. 724 , 66 S. Ct. 29 (1945).

11971–1971
Curtis v. Utah Fuel Co. green
scotus · 1945
1 sentence

1971This is so because, by definition, the communication is published in furtherance of some overriding .social interest and is therefore not “wrongful.” Nevertheless, if the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated: Bausewine v. Norristown Herald, 351 Pa. 634 , 41 A. 2d 736 , cert. denied, 326 U.S. 724 , 66 S. Ct. 29 (1945).

11971–1971
Bausewine v. Norristown Herald, Inc. green
pa · 1945
2 sentences

1971This is so because, by definition, the communication is published in furtherance of some overriding .social interest and is therefore not “wrongful.” Nevertheless, if the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated: Bausewine v. Norristown Herald, 351 Pa. 634 , 41 A. 2d 736 , cert. denied, 326 U.S. 724 , 66 S. Ct. 29 (1945).

1971This is so because, by definition, the communication is published in furtherance of some overriding .social interest and is therefore not “wrongful.” Nevertheless, if the privileged occasion is but a qualified one and it be shown that defendant was actuated by malice, the defense of qualified privilege is vitiated: Bausewine v. Norristown Herald, 351 Pa. 634 , 41 A. 2d 736 , cert. denied, 326 U.S. 724 , 66 S. Ct. 29 (1945).

11971–1971
State v. Wojculewicz neutral
conn · 1953
1 sentence

1969The function of malice in a libel case is to refute the defense of qualified privilege: Williams v. Kroger Grocery & Baking Company, 133 Pa. Superior Ct. 1 , 101 A.2d 495 (1938).

11969–1969
Williams v. Kroger Grocery & Baking Co. green
pasuperct · 1938
1 sentence

1969The function of malice in a libel case is to refute the defense of qualified privilege: Williams v. Kroger Grocery & Baking Company, 133 Pa. Superior Ct. 1 , 101 A.2d 495 (1938).

11969–1969
Neeb v. Hope green
pa · 1886
2 sentences

1938The jury could find actual malice from the falsity of the accusations and the want of probable cause (Neeb v. Hope, 111 Pa. 145, 154 , 2 A. 568 ).

1938The jury could find actual malice from the falsity of the accusations and the want of probable cause (Neeb v. Hope, 111 Pa. 145, 154 , 2 A. 568 ).

11938–1938

Where else courts name it

NY 46 (1944–2024) TX 35 (1978–2024) OH 34 (1980–2026) NC 29 (1963–2022) NJ 20 (1975–2025) AL 18 (1991–2025) CA 15 (1921–2017) MA 14 (1991–2026) CT 12 (1992–2009) MD 11 (1959–2020) FL 11 (1981–2010) NM 10 (1964–2024) MI 9 (1987–2019) PA 9 (1938–2025) MO 9 (1954–2000) DC 8 (1970–2024) WV 8 (1943–2023) CO 7 (1990–2002) WY 7 (1989–2021) SC 7 (1962–2015) LA 6 (1977–2008) IA 6 (1972–2013) MS 6 (1991–2005) WI 6 (1987–2000) AZ 6 (1970–2011) SD 6 (1993–2021) TN 5 (1996–2011) GA 5 (1992–2015) WA 4 (1978–2024) KS 4 (1994–2013) VA 4 (1985–2014) IN 4 (1977–1989) OK 4 (1981–2017) OR 4 (1960–2012) ME 3 (1998–2023) ID 3 (1987–2004) IL 3 (1975–2006) AR 3 (1987–2013) NE 2 (1931–1999) VT 2 (2024–2024) MN 2 (1994–1997) RI 2 (1992–2023)

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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