Matter of W.S. v. G.S.
The petitioner (W.S.) filed a family offense petition against the respondent (G.S.), his sister, alleging harassment in the second degree. W.S. claimed G.S. threatened 'further consequences' and made false statements in a Mental Hygiene Law article 9 petition, leading to W.S.'s arrest. G.S. argued her statements were privileged and made due to genuine fear and concerns about W.S.'s mental health and hoarding. The court held that communications made in support of a Mental Hygiene Law petition are subject to a qualified privilege and serve a 'legitimate purpose' unless made with knowing/reckless disregard of falsity and solely to alarm/annoy. The court found W.S. failed to prove G.S.'s statements met this higher standard or that her other alleged actions constituted harassment. Consequently, the petition was dismissed.