Oberbroeckling v. Lyle

This is a defamation case among private individuals and a private corporation arising from an employer-employee relationship. The controlling question is whether the trial court erred in ruling that the evidence was insufficient to establish the requisite malice to recover upon a qualifiedly privileged communication.

The controversy arose from the management of Lake Land’Or, a recreational community in Caroline County. Appellee Lake Land’Or Property Owners Association, a Virginia corporation and a defendant below, was formed in the mid-1970s. The Association had approximately 2,000 property…