Pamela Moses v. Terry Roland
Pamela Moses sued Terry Roland, a former county commissioner, for defamation and negligent/intentional infliction of emotional distress, alleging Roland made false statements about her during county legislative meetings. Roland asserted immunity under the Tennessee Governmental Tort Liability Act and argued his statements were not defamatory. The trial court found Roland liable for defamation regarding statements that Moses should be watched by Homeland Security and that she threatened 'everybody'. The Court of Appeals reversed the trial court's decision, finding Roland immune for the Homeland Security statements and concluding that the 'threatened everybody' statement was rhetorical hyperbole, thus not defamatory as a matter of law.