Rosenberg v. MetLife, Inc.

The National Association of Securities Dealers (“NASD”) requires its members to file a termination form (“Form U-5”) whenever they terminate a registered employee. The form contains the employer’s statement of the reasons for the termination, and the NASD provides the form to any member firm upon request. This case presents the question of whether an employee may base an action for libel on statements on a Form U-5.

In a July 19, 2005 judgment of the United States District Court for the Southern District of New York (Jed S. Rakoff, Judge), the district court held that such statements are…