McAulay v. Maloff

Plaintiff, a former teacher at Seward Park High School, commenced this action for defamation against her former principal at the school. Defendant moves for summary judgment dismissing the complaint on the ground that the alleged libelous material was contained in an official report made to the superintendent of schools and that he, as principal, must be accorded the protection of absolute privilege.

At the close of each school year the principal was required to submit a report to the superintendent of schools evaluating the work of each teacher as "satisfactory” or "unsatisfactory”. If the…