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Chamberlain v. Mathis

Arizona Supreme Court

729 P.2d 905 (1986)

Facts

The Arizona Department of Health Services (ADHS) employed William Chamberlain, Wilda Dearie, Sue Ann Gundy, Arthur Reeves, and Michael Savino (ADHS employees) (plaintiffs). The ADHS employees performed an audit of an administrator contract. ADHS director Donald Mathis (defendant) publicly criticized the audit and made negative remarks about the ADHS employees, which included calling the ADHS employees incompetent and unqualified. These remarks were published in the newspaper the Arizona Republic. The ADHS employees brought a defamation action against Mathis. The trial court dismissed the claim, holding that Mathis enjoyed absolute immunity as an executive official. The ADHS employees appealed. The appellate court reversed, holding that Mathis’s immunity posed a fact question. Mathis appealed. The Arizona Supreme Court granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Feldman, J.)

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A "yes" or "no" answer to the question framed in the issue section;
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