Shannon v. Taylor AMC/Jeep, Inc.
Michigan Court of Appeals
425 N.W.2d 165 (1988)
Facts
Shannon (plaintiff) worked as a parts manager for Taylor AMC/Jeep, Incorporated (Taylor) (defendant). Shannon alleged that he suspected someone was attempting to sell stolen parts to Taylor. Shannon contacted James Black, a friend who was a police officer, for advice. Black advised Shannon that he needed to collect hard evidence. Shannon purchased two Jeep hardtops that he suspected were stolen and put them in the parts department. An employee indicated to Shannon that a customer wanted to purchase one of the hardtops, but Shannon informed the employee that the hardtops were not for sale because they might have been stolen. Taylor fired Shannon. Shannon alleged that Black was going to write a police report on the stolen goods the same day. After his termination, the new parts manager, Laurie Cherup, was overheard telling customers that Shannon had been fired for getting caught stealing and being involved in the theft of parts. Shannon filed an action against Taylor for defamation. Taylor argued that it had a qualified privilege to communicate with its customers because the customer relationship would be damaged if the customers discovered that they had been sold stolen parts. The trial court found that Cherup’s statements were protected by qualified privilege. Shannon appealed.
Rule of Law
Issue
Holding and Reasoning (McDonald, J.)
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