Ashton-Blair v. Merrill

OPINION

VOSS, Judge.

Scott Ashton-Blair appeals from the summary judgment in favor of Frederick D. Merrill. We must determine whether a respondent to a bar complaint is privileged to make defamatory statements against a complainant-attorney in his response to the complaint. We hold that an absolute privilege applies to statements related to the pending proceeding and affirm the judgment.

BACKGROUND 1

Ashton-Blair filed a complaint with the State Bar of Arizona against Merrill. In his response, Merrill explained and defended his conduct in his dealings with two former clients. Merrill also…