Pisharodi v. Barrash
Appellant, Dr. Madhaven Pisharodi, challenged a trial court's award of summary judgment in favor of appellees, Dr. J. Martin Barrash and Houston Neurosurgical Associates, P.A., on a libel claim. Dr. Pisharodi sued Dr. Barrash for statements made in a letter concerning his medical treatment of a patient, Juan Escobedo. The trial court concluded that the contested statements were pure opinions and were absolutely privileged because they were published in connection to a quasi-judicial proceeding involving the United States Department of Labor. The appellate court reversed this judgment, concluding that the letter was capable of defamatory meaning and not protected opinion speech. Furthermore, the court found a genuine issue of material fact regarding whether the letter was republished outside the privileged judicial context, thus waiving the privilege. The case was remanded for further proceedings.