Carradine v. Minnesota

511 N.W.2d 733 (1994)

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Carradine v. Minnesota

Minnesota Supreme Court
511 N.W.2d 733 (1994)

  • Written by Lauren Petersen, JD

Facts

Robert Carradine (plaintiff) was a racecar driver and actor. While driving to the airport, he was stopped by a Minnesota state trooper, Patrick Chase (defendant). Chase arrested Carradine, and Carradine was booked and held for 10 hours before being released. In Chase’s arrest report, he stated that Carradine’s conduct had included speeding, reckless driving, fleeing an officer, and impersonating an officer. Chase made similar statements to jail personnel, prosecutors, and to a reporter. The news of Carradine’s alleged conduct spread to several newspapers and television outlets. Carradine sued Chase and the state of Minnesota for, among other things, defamation. The defendants moved for summary judgment. The trial court granted summary judgment in favor of the defendants for all but three claims. One of the three denied claims was defamation. The defendants appealed the denial, arguing that as a state officer, Chase enjoyed absolute immunity from defamation suits. The court of appeals affirmed the trial court, holding that Chase did not have absolute immunity in regard to the statements he made in his arrest report or to the press. The defendants sought review of the case by the supreme court, and the supreme court granted review.

Rule of Law

Issue

Holding and Reasoning (Coyne, J.)

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