Cited by

“We apply de novo review to the district court’s denial of a Rule 50 motion.” Bahr v. Boise Cascade Corp.

-19 (Minn. 2009); Schmitz v. Rinke, Noonan, Smoley, Deter, Colombo, Wiant, Von Korff and Hobbs, Ltd.

Bahr v. Boise Cascade Corp ., –19 (Minn. 2009).

“ [I]f the plaintiff presents evidence that the utterer knew the falsity of his statements when published, such bad faith in publishing is relevant evidence of malice”

Bahr v. Boise Cascade Corp. , (M inn.

App. P. 103.04; see also Bahr v. Boise Cascade Corp. , -19 (Minn. 2009) (discussing the rea ch of Minn. R. Civ.

“Malice is not proved merely by the fact that the statement has been made or by the fact that the statement is later proven to be false.”

g that Pehrson’s statements to police were defamatory.3 “To establish a defamation claim, a plaintiff must prove three elements: (1) the defamatory statement is communicated to someone other than the plaintiff; (2) the statement is false; and (3) the statement tends to harm the plaintiff’s reputation and to lower the plaintiff in the estimation of the community.” -20 (Minn. 2009) (quotation omitted).

Jerry’s Enters., Inc., v. Larkin, Hoffman, Daly & Lindgren, Ltd., Appellate courts “apply de novo review to the district court’s denial of a [r]ule 50 motion.” aff’d

P. 50.01, the court may grant judgment as a matter of law if a party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue.” (quotation omitted).

“[S]tatements made in the course of an employer’s investigation into employee misconduct are protected by the qualified privilege.”

“‘[S]tandards for granting summary judgment and for granting [JMOL] are the same.’” (quoting Hoover v. Norwest Private Mortg.

(stating that, after a jury trial, “a denial of a motion for summary judgment .

“Actual malice requires a showing that the defamatory statements are made from ill will and improper motives, or causelessly and wantonly for the purpose of injuring the plaintiff.” (quotation omitted).

common-council member Michael] Wojcik defamed them.” “To establish a defamation claim, a plaintiff must prove three elements: (1) the defamatory statement is communicated to someone other than the plaintiff, (2) the statement is false, and (3) the statement tend[s] to harm the plaintiffs reputation and to lower [the plaintiff] in the estimation of the community.” *464 -20 (Minn.2009) (quotation omitted).

Co., rev’d on other grounds

To establish the elements of a defamation claim in Minnesota, a plaintiff must prove that: (1) the defamatory statement was “communicated to someone other than the plaintiff’; (2) the statement is false; (3) the statement tends to “harm the plain *730 tiffs reputation and to lower [the plaintiff] in the estimation of the community,” -20 (Minn.2009); and (4) “the recipient of the false statement reasonably understands it to refer to a specific individual.”