Lega Siciliana Social Club v. St. Germaine

Lega Siciliana Social Club (the club) (plaintiff) purchased a former school building from the city of Waterbury. The club then received a zoning change for the building from Waterbury, despite the objections of neighborhood residents, including Robert St. Germaine, Sr. (defendant). In the building, the club operated a social club for individuals of Sicilian ancestry. Later, the club applied for and received a liquor license. St. Germaine and other residents disapproved of the club, believing that the liquor license and the club itself changed the character of their neighborhood. St. Germaine was also upset because he believed he was not given adequate notice of the club’s liquor-license application. Some months after the club received its liquor license, St. Germaine wrote a letter to the president of the board of aldermen for Waterbury, copying both the board of aldermen’s minority leader and the zoning board. In the letter, St. Germaine accused the club of having political connections and Mafia connections, allowing it to get rubber-stamp approval of whatever it wanted. The club filed a defamation suit against St. Germaine for the accusations in his letter. St. Germaine moved for summary judgment, and the court granted the motion, finding that the accusations in the letter were not libel per se and that the club had not proved the accusations had caused the club cognizable damages or harm. The club appealed.