Sigal Construction Corp. v. Stanbury

Sigal Construction Corporation (Sigal) (defendant) employed Kenneth Stanbury (plaintiff) as a project manager for approximately one year. After Sigal terminated Stanbury’s employment, Stanbury received a job offer on a new project contingent upon the approval of the project owner, Lincoln Properties (Lincoln). William Janes, a Lincoln general partner, contacted Paul Littman, a Sigal project executive, for a reference on Stanbury. Littman told Janes that (1) Stanbury seemed detail oriented to the point of losing sight of the big picture; (2) with a large staff, Stanbury might be a very competent project manager; and (3) obviously Stanbury no longer worked for Sigal, which might say enough. Littman had never worked on a project with Stanbury and based his representations on a general impression that Littman had developed from hearing people talk about Stanbury’s work. Littman made no effort to verify this information before relaying it to Janes. Janes, on the other hand, believed that Littman had personal knowledge of Stanbury’s performance and stated that Littman told him he had worked with Stanbury on a project. Stanbury was not hired for the new project because of Littman’s negative reference. Stanbury sued Sigal for defamation, and a jury returned a verdict in Stanbury’s favor. The trial court denied Sigal’s motion for judgment notwithstanding the verdict, and Sigal appealed.