Hecht v. Levin

We are asked to decide what privilege attaches to statements made in a grievance filed with a certified grievance committee of a local bar association. For the reasons stated below, we hold that it is an absolute privilege.

As an initial matter, we address Levin’s argument that Hecht cannot maintain a defamation action because the filing of a grievance, which is confidential, is not a publication. The publication of defamatory matter is an essential element to liability for defamation. “Publication of defamatory matter is its communication intentionally or by a negligent act to one other than…