New York Court of Appeals
Alfred L. Shapiro v. Health Insurance Plan of Greater New York
November 25, 19597 N.Y.2d 56
Summary
The New York Court of Appeals reversed the lower courts and granted summary judgment to the defendants, holding that the plaintiff failed to produce evidence of actual malice required to overcome the qualified privilege protecting the defendants' statements. The court affirmed that the burden of proving actual malice rests on the plaintiff and that suspicion or prior disputes do not satisfy that burden.