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Garcia v. Hilton Hotels International, Inc.

United States District Court for the District of Puerto Rico
97 F.Supp. 5 (D.P.R. 1951)


Facts

Garcia (plaintiff) brought a defamation suit against his former employer, Hilton Hotels International, Inc. (Hilton) (defendant). Paragraph 4 of Garcia’s complaint alleged that he was “violently discharged by the defendant, being falsely and slanderously accused of” bringing prostitution to a Hilton hotel. Paragraphs 5-8 of Garcia’s complaint alleged that he filed a claim with Puerto Rico’s labor department for severance pay and that at the hearing on the claim, Hilton repeated its statement that Garcia brought prostitution to the hotel. Hilton filed a motion to dismiss based on failure to state a claim, or, alternatively, a motion to strike paragraph 5-8 and for a more definite statement of the complaint. Hilton argued (1) that the statements made when firing Garcia (paragraph 4) were not published and thus were not defamatory, (2) that it had a qualified privilege to make the statements in paragraph 4, and (3) that it had an absolute privilege to make the statements at the hearing (paragraphs 5-8).

Rule of Law

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Issue

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Holding and Reasoning (Roberts, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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