Adams v. Peck

This case presents the novel question whether an absolute privilege applies to a defamatory statement published in a document which is prepared for possible use in connection with a pending judicial proceeding but which has not been filed in that proceeding.

In July, 1976, in the Circuit Court for Baltimore County, the appellant, Peter R. Adams (father), and Caryl W. Adams (mother), were engaged in a contested divorce proceeding. In August, 1976, they entered into a separation agreement in which the mother was granted custody of the two minor children and the father was granted visitation…