Quigley v. Rosenthal

William and Dorothy Quigley (plaintiffs) owned a home in Colorado. A dispute arose between the Quigleys and their neighbors, Mitchell and Candice Aronson, who were Jewish. Throughout the course of the dispute, the Aronsons met with the Anti-Defamation League (ADL) (defendant) and the ADL’s attorney, Saul Rosenthal (defendant), on numerous occasions. Eventually, the Aronsons filed a civil lawsuit against the Quigleys, alleging various anti-Semitic actions on the Quigleys’ part. Based on their familiarity with the Aronsons and the underlying facts, at the time of the lawsuit, the ADL and Rosenthal either knew or were in a position to know that the Aronsons’ allegations of religious discrimination were baseless. Nonetheless, shortly after the filing of the lawsuit, Rosenthal and the ADL called a press conference under the ADL’s name to amplify and call media attention to the Aronsons’ lawsuit. In response, the Quigleys brought a defamation action in federal district court against the ADL and Rosenthal, based on statements Rosenthal had made at the press conference. The ADL and Rosenthal moved for summary judgment, arguing that they could not be liable for defamation because even though the Quigleys were not public figures, the statements involved matters of public concern. The district court rejected the ADL and Rosenthal’s argument, finding that the statements did not relate to a matter of public concern; the court reasoned that at the time of the press conference, the underlying dispute between the Quigleys and the Aronsons was private. Rosenthal and the ADL appealed. On appeal, Rosenthal and the ADL argued that civil litigation was always, or nearly always, a matter of public concern. Rosenthal and the ADL also argued that religious discrimination was by necessity a matter of public concern.