Williams v. Garraghty

These consolidated appeals from a single judgment present various issues arising out of a plaintiffs recovery of damages in a defamation action.

I

David A. Garraghty, a prison warden employed by the Virginia Department of Corrections (the Department), sued Gloria B. Williams, a subordinate employee, seeking damages for defamation, insulting words, and intentional and negligent infliction of emotional distress resulting from a memorandum written by Williams. In the memorandum, Williams accused Garraghty of sexual harassment.

Williams filed a demurrer to Garraghty’s motion for judgment,…