Olguin v. Santa Barbara Community College Dist.
A psychology professor at a community college distributes to his colleagues a memo that is highly critical of the psychology department chairperson. We conclude the memo falls within the zone of protected speech and is therefore not actionable.
Plaintiff Arthur Olguin, a psychology professor, appeals a judgment in favor of defendants Santa Barbara Community College District (District) and Raymond Launier, a District psychology professor. Launier filed a grievance against Olguin and sent a memo to District colleagues. Launier claimed that Olguin violated academic freedom when Olguin instructed the college bookstore not to order materials Launier authored and planned to use in his classes. Olguin stated the memo contained false statements including the "republication" of a student's complaint to the District about witnessing him commit a lewd act in his office. Olguin sued defendants, alleging multiple causes of action, including defamation, intentional infliction of emotional distress, and negligence by the District for hiring and not supervising Launier. Launier claimed his academic freedom memo fell within a conditional privilege. The jury found Launier did not act with malice.
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