Sanderson v. Bellevue Maternity Hospital, Inc.
Plaintiff, an at-will employee, was removed from her position at Bellevue Maternity Hospital by her supervisor, Susan Fraley, following a co-worker's allegation of harassment. Plaintiff initiated a lawsuit against the co-worker for defamation and tortious interference, and against Bellevue and Fraley for defamation and wrongful discharge. The Supreme Court dismissed the defamation claim against Bellevue and Fraley, citing qualified privilege, and the wrongful discharge claim against Bellevue, upholding the principle of at-will employment. This appeal affirms the dismissal of the defamation claim against Bellevue and Fraley, concluding that Fraley's statements were protected by qualified privilege and the plaintiff failed to demonstrate actual malice. The court also noted the abandonment of the wrongful discharge claim on appeal.