Brown (plaintiff) was a licensed contractor. Kelly Broadcasting Company (Kelly) (defendant) broadcast a story on the local news indicating that Brown performed incomplete and shoddy work for one of her clients. Brown brought suit for defamation. Kelly argued that state law provided a public-interest privilege, under which the news media could not be liable for defamation if the allegedly defamatory statement concerned a matter of public interest. For support, Kelly relied on an interested-person privilege under California state law. The state statute established a privilege for communications made without malice between persons with a shared interest in the subject matter of the communication. The trial court granted summary judgment to Kelly, and the court of appeal reversed. Kelly appealed.