Coyne v. O'Connor

In this action for libel, based on defendant’s letter to the Industrial Commissioner of the State of New York, the defendant moves for summary judgment.

It appears that the plaintiff formerly worked for the defendant and was discharged. In connection with his application to the commissioner for unemployment benefits, the defendant was required to disclose the reason for the discharge. This he did in the letter complained of.

The defendant was not a free agent in making this disclosure. Regulation No. 28, adopted by the commissioner under the authority conferred by section 530 of the Labor Law,…