Philip M. McQuirk v. Louis Kevin Donnelley, Sheriff Glenn County Glenn County

TASHIMA, Circuit Judge:

Philip McQuirk, a former employee of the Glenn County, California, Sheriffs Office, applied for a job with the Mountlake Terrace, Washington, Police Department. The day before McQuirk was to begin working, Louis Donnelley, the Sheriff of Glenn County, made a number of allegedly defamatory statements about McQuirk’s performance as an employee of the Glenn County Sheriffs Office to Commander Scott Smith of the Mountlake Terrace Police Department. As a result of these statements, Smith rescinded the offer of employment to McQuirk. McQuirk sued Donnelley and Glenn County…