Board of Forensic Document Exa v. American Bar Association

Scudder, Circuit Judge.

The Board of Forensic Document Examiners brought a defamation action alleging reputational harm from an article published in an American Bar Association law journal. The district court dismissed the action, concluding that the article did not sufficiently identify the Board or any of its members as the subjects of criticism and, even if it had, expressed nothing more than the author's opinion. Because we agree that the statements are non-actionable, constitutionally protected expressions of opinion, we affirm.

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