Three Maine school district employees who were sued for defamation after they criticized a principal’s actions should have been allowed to raise a defense under a state law limiting strategic litigation against public participation, or SLAPP suits, a federal appeals court has ruled.
A three-judge panel of the U.S. Court of Appeals for the 1st Circuit, in Boston, ruled unanimously for the school employees who were sued by Pat Godin, the former principal of Fort O’Brien Elementary School in Machiasport, Maine. The three employees had made statements to district administrators that Godin had acted abusively towards students. A 2008 school district investigation found that the charges of abusive conduct were not supported, court papers say.
However, Godin’s contract was terminated early, purportedly for budgetary reasons, and the principal sued the employees for defamation and the Machiasport school district for alleged violation of her due process rights.
A federal district court ruled last year that the individual defendants could not raise Maine’s anti-SLAPP statute in federal court because it conflicted with federal rules of civil procedure. Anti-SLAPP laws are meant to give defendants procedures to quickly dismiss meritless litigation that chills public participation and protected speech.
In its Dec. 22 decision in Godin v. Schencks, the 1st Circuit court panel ruled that the individual defendants should have been allowed to raise the anti-SLAPP defenses to the defamation suit.
“Because [Maine’s anti-SLAPP law] is so intertwined with a state right or remedy that it functions to define the scope of the state-created right, it cannot be displaced” by federal civil procedural rules, the appeals court said.
The court remanded the case to the district court for further proceedings.