Cited by
Opinions in Minnesota that cite Johnson v. Dirkswager, 315 N.W.2d 215.
- Thaleaha McBee v. Team Industries, Inc. Minn. 2025
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Thaleaha McBee v. Team Industries, Inc.
Minn. 2025
1103, 1103 (Minn. 1895) (considering whether statements published in a court pleading are “absolutely privileged” and may not “be made the basis of an action for libel or slander”); (statements made by participants in judicial proceedings are absolutely privileged and “will not support a civil action for defamation”); d 215, 223 (Minn. 1982) (high-level agency official “has an absolute privilege, in the performance of .
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Minn. 2025
1103, 1103 (Minn. 1895) (considering whether statements published in a court pleading are “absolutely privileged” and may not “be made the basis of an action for libel or slander”); (statements made by participants in judicial proceedings are absolutely privileged and “will not support a civil action for defamation”); d 215, 223 (Minn. 1982) (high-level agency official “has an absolute privilege, in the performance of .
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A24-1331
Minn. Ct. App. 2025
see also Harlow, d at 572-73 (determining that a deputy commissioner is “a top-level cabinet-equivalent official” and concluding that “a deputy commissioner of DHS, whose position and duties are defined by Minn. Stat. § 15.06, subd.
- State of Minnesota v. Larry Joe Foster Minn. 2025
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State of Minnesota v. Larry Joe Foster
Minn. 2025
tor vehicle, we do not address that issue.”); d 541, 551 n.4 (Minn. 2010) (noting that, because the parties did not raise an issue, the issue was not before the court); n.4 (Minn. 1998) (declining to address an issue discussed by the court of appeals because neither party raised it before the supreme court); (electing not to base the court’s decision on an issue that appellants did not raise or brief).
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Ryan Larson,
Minn. 2020
d faith, on a proper occasion, with a proper motive, and upon reasonable or probable 4 We have applied an absolute privilege to statements made by participants in judicial proceedings, statements made by a high-level agency official in the performance of official duties, and statements made by a state trooper in a written arrest report, –37 (Minn. 1994).
- Heilman v. Courtney 926 N.W.2d 387 Minn. 2019
- Michael Harlow v. State of Minnesota Department of Human Services 883 N.W.2d 561 Minn. 2016
- Michael Harlow v. State of Minnesota Department of Human Services 883 N.W.2d 561 Minn. 2016
- Jerry Expose, Jr. v. Thad Wilderson & Associates, P. A., Nina Mattson 863 N.W.2d 95 Minn. Ct. App. 2015
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Jerry Expose, Jr. v. Thad Wilderson & Associates, P. A., Nina Mattson
863 N.W.2d 95
Minn. Ct. App. 2015
(holding that state official was entitled to absolute privilege because he was “required by law,” i.e., data privacy act, to disclose reason for termination of plaintiff’s employment).
- Michael Harlow v. State of Minnesota Department of Human Services 862 N.W.2d 704 Minn. Ct. App. 2015
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Michael Harlow v. State of Minnesota Department of Human Services
862 N.W.2d 704
Minn. Ct. App. 2015
2(a)(5); (“[I]t is no violation of the [MGDPA] to tell the reporter about the contents of a public document.”).
- Minke v. City of Minneapolis 845 N.W.2d 179 Minn. 2014
- Minke v. City of Minneapolis 845 N.W.2d 179 Minn. 2014
- Zutz v. Nelson 788 N.W.2d 58 Minn. 2010
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Zutz v. Nelson
788 N.W.2d 58
Minn. 2010
(acknowledging the extension of absolute privilege to government officials acting in judicial or quasi-judicial capacities); (extending absolute privilege to Commissioner of Public Welfare in the performance of his official duties as a “top-level cabinet-type” official).
- Lake v. Wal-Mart Stores, Inc. 582 N.W.2d 231 Minn. 1998
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Lake v. Wal-Mart Stores, Inc.
582 N.W.2d 231
Minn. 1998
§ 548.06 (1996) (providing that published retraction may mitigate damages); (absolute privilege in defamation for public service or administration of justice); Mahnke v. Northwest Publications Inc., 280 Minn. 328, (conditional privilege regarding public officials and candidates for office — official must prove actual malice); Friedell v. Blakely Printing Co., 1
- Buchanan v. Minnesota State Department of Health 573 N.W.2d 733 Minn. Ct. App. 1998
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Buchanan v. Minnesota State Department of Health
573 N.W.2d 733
Minn. Ct. App. 1998
The purpose of an absolute privilege is to promote the public good by keeping “the public informed of the public’s business,” and its application “should be confined to situations where the public service or the administration of justice requires it.”
- Kellar v. VonHoltum 568 N.W.2d 186 Minn. Ct. App. 1997
- Kellar v. VonHoltum 568 N.W.2d 186 Minn. Ct. App. 1997
- Redwood County Telephone Co. v. Luttman 567 N.W.2d 717 Minn. Ct. App. 1997
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Redwood County Telephone Co. v. Luttman
567 N.W.2d 717
Minn. Ct. App. 1997
the supreme court first recognized that an absolute privilege to make defamatory communications applied to a public executive official.
- Bol v. Cole 561 N.W.2d 143 Minn. 1997
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Bol v. Cole
561 N.W.2d 143
Minn. 1997
See, -37 (Minn.1994); -23 (Minn.1982).
- Zagaros v. Erickson 558 N.W.2d 516 Minn. Ct. App. 1997
- Zagaros v. Erickson 558 N.W.2d 516 Minn. Ct. App. 1997
- Carter v. Peace Officers Standards & Training Board 547 N.W.2d 431 Minn. Ct. App. 1996
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Carter v. Peace Officers Standards & Training Board
547 N.W.2d 431
Minn. Ct. App. 1996
(describing positions entitled to absolute immunity).
- Hegner v. Dietze 524 N.W.2d 731 Minn. Ct. App. 1994
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Hegner v. Dietze
524 N.W.2d 731
Minn. Ct. App. 1994
2d 654, 658 (1971) (general counsel and general manager of subordinate economic organization of tribe absolutely immune from suit); -91 (Minn.App.1994) (Indian tribe’s sovereign immunity extended to tribe’s attorney; attorney had absolute immunity to publish defamatory statement made in course of duties as tribal spokesperson); (Commissioner of Department of Public Welfare had an absolute privilege to publish defamatory statement).
- Diver v. Peterson 524 N.W.2d 288 Minn. Ct. App. 1994
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Diver v. Peterson
524 N.W.2d 288
Minn. Ct. App. 1994
(high level executive officers have absolute immunity from suit for defamatory statements made in the course of their duties).
- BD. OF REGENTS OF U OF M v. Reid 522 N.W.2d 344 Minn. Ct. App. 1994
- BD. OF REGENTS OF U OF M v. Reid 522 N.W.2d 344 Minn. Ct. App. 1994
- Carradine v. State 511 N.W.2d 733 Minn. 1994
- Bauer v. State 511 N.W.2d 447 Minn. 1994
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Bauer v. State
511 N.W.2d 447
Minn. 1994
the Commissioner of Welfare was sued for defamation by a state hospital superintendent whose termination he had announced.
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Carradine v. State
511 N.W.2d 733
Minn. 1994
we held, unanimously, that the Commissioner of the Minnesota Department of Public Welfare — who is obviously a high level executive officer — enjoys such immunity.
- Villarreal v. Independent School District 659 505 N.W.2d 72 Minn. Ct. App. 1993
- Villarreal v. Independent School District 659 505 N.W.2d 72 Minn. Ct. App. 1993
- Waste Recovery Cooperative of Minnesota v. County of Hennepin 504 N.W.2d 220 Minn. Ct. App. 1993
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Waste Recovery Cooperative of Minnesota v. County of Hennepin
504 N.W.2d 220
Minn. Ct. App. 1993
(due care in the execution of a statute immunity under Minn.Stat.
- LeBaron v. Minnesota Board of Public Defense 499 N.W.2d 39 Minn. Ct. App. 1993
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LeBaron v. Minnesota Board of Public Defense
499 N.W.2d 39
Minn. Ct. App. 1993
Restatement (Second) of Torts § 591 (1977).
- Carradine v. State 494 N.W.2d 77 Minn. Ct. App. 1992
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Carradine v. State
494 N.W.2d 77
Minn. Ct. App. 1992
2(c), 3, 4(f), 16 (1986) and the Minnesota Supreme Court’s