Hartman v. Keri

DARDEN, Judge,

dissenting.

I respectfully dissent to the majority's conclusion that absolute privilege applies here.

First, I would find that the statements by Hartman and Swinehart are only entitled to possible protection as qualified privilege. I do not believe the proceedings provided by Purdue rise to the level of "judicial process" because they lack the inherent protections of the judicial process. The Procedures themselves state that they "are not those of a court of law, and the presence of legal counsel for the parties is not permitted during the conduct of these Procedures." (App. 353). Without representation by counsel, the Procedures do not provide for cross-examination of adverse witness statements. Also, the adverse statements made in the course of the Procedures are not made under oath, subject to the penalties of perjury. The majority also notes that the Procedures "specifically require investigation into and protection from knowingly false or malicious charges." Op. at 1029. However, the "remedy" provided by C-83 for bring*1032ing a false charge, or "a charge of harassment in bad faith," is disciplinary action by Purdue against the person who brought that charge-not a legal remedy for the person falsely charged. It is precisely because the Procedures fail to provide to Keri the inherent protections of the judicial process that I would find that the privileges here must be found to be qualified-thereby requiring "a trier of fact to determine whether the privilege has been abused." Op. at 1080.

Further, I would find that there is a material question of fact as to whether Hartman and Swinehart abused that privilege. A communication may be protected by "qualified privilege if a need exists for full and unrestricted communication regarding matters on which the parties have a common interest or duty." Olsson v. Indiana Univ. Bd. of Trs., 571 N.E.2d 585, 587 (Ind.Ct.App.1991), trans. denied. It seems clear to me that Purdue, its faculty, and it students have a common interest in the "report[ing] and address[ing] of incidents of harassment." (App. 348). Under the qualified privilege rule, a communication is privileged if made in good faith on any subject matter in which the party making the communication has an interest if made to a person having a corresponding duty. Id. However, as cited by the majority, the protection of the qualified privilege applies to communication "made in good faith." Ind. Nat'l Bank v. Chapman, 482 N.E.2d 474, 479 (Ind.Ct.App. 1985), trans. demied. Thus, application of the privilege "does not change the actionable quality of the words published" because the trier of fact may still "determine the privilege was abused by ... lack of belief or grounds for belief in the truth of what is said." Id. at 479, 480.

I find that whether statements made by Hartman and Swinehart in the course of reporting and addressing allegations of harassment were made in "good faith" is a question of fact. The Procedure's specific omissions of protection for Keri that would be provided by the judicial process-representation by counsel, testimony under oath, cross-examination, a legal remedy-lead me to conclude that the statements made therein should be subject to and tested by the crucible of trial. The credibility of those who made the adverse statements, Hartman and Swinehart, should be put to that test. Therefore, I would affirm the trial court.