Singh v. Sukhram
This case addresses whether the Noerr-Pennington doctrine applies to libel claims. The plaintiff, an airline executive, sued defendants Frank Singh and Buddy D. Ramsaran for libel based on objections they filed with the U.S. Department of Transportation (DOT) concerning his application for air service authority. The defendants' objections contained allegations of the plaintiff's dishonesty and mismanagement in prior ventures. The Supreme Court denied the defendants' motions to dismiss. The appellate court affirmed, holding that the Noerr-Pennington doctrine does not apply to libel, but rather a qualified privilege requiring proof of malice. The court found the 'sham' exception to Noerr-Pennington was not met, but that the plaintiff had sufficiently alleged malice to proceed with the libel claim under CPLR 3211(a)(7) and Civil Rights Law § 76-a.