Cohen v. Hartlage

Beasley, Judge.

Plaintiff Cohen appeals from the grant of defendant Hartlage’s motion for summary judgment in an action for libel alleging that a report Hartlage made to the Georgia Board of Examiners of Psychologists (Board) contained false and defamatory statements. Hartlage defended and moved for summary judgment on the basis that the report was privileged under OCGA § 51-5-7.

Cohen was a psychology intern at the Medical College of Georgia. Hartlage was the supervisor under whom Cohen was required to spend a certain minimum number of hours in order to secure his license. Early intern…