Southeastern Tidewater Opportunity Project, Inc. v. Bade

In this appeal of a judgment in favor of a plaintiff who had filed a defamation action against defendants who enjoyed a qualified privilege, we consider whether the plaintiff proved malice by clear and convincing evidence.

Plaintiff, Paul F. Bade, was employed as the comptroller for the Southeastern Tidewater Opportunity Project, Inc. (“STOP”). L. Louise Lucas served as executive director of STOP. As comptroller, Bade reported to Lucas and, on certain occasions, to the STOP board of directors.

Before Bade was hired as the comptroller, STOP had experienced budget deficits and fiscal problems,…