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Flamm v. American Association of University Women

United States Court of Appeals, Second Circuit
201 F.3d 144 (2000)


Facts

The American Association of University Women and the AAUW Legal Advocacy Fund (AAUW) (defendants) compiled and distributed a directory listing the names and contact information of 275 attorneys and specialists willing to consult with women in discrimination cases. The entry for Flamm (plaintiff) contained the only negative comment in the directory, stating that at least one plaintiff had described Flamm and an “ambulance chaser” only interested in “slam dunk cases.” Flamm sued, claiming this description constitutes libel per se. The district court granted AAUW’s motion to dismiss, finding that the statement could not reasonably be found to be a statement of objective fact. Flamm appealed.

Rule of Law

Issue

Holding and Reasoning (Meskill, J.)

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