Cited by

Opinions in Minnesota that cite Bol v. Cole, 561 N.W.2d 143.

67 citing documents.

A25-1008 N A BROTHERS LLC, d/b/a Goddard School of Albertville v. Heather Werts, et al. (A25-0930) (A25-1002, A25-1008), … Minn. Ct. App. 2026
“There is a strong public interest in reporting child abuse and protecting children from further abuse.” Bol v. Cole
Brenda Thormodson, et al v. Kathryn Rae Zehnder Minn. Ct. App. 2025
Brenda Thormodson, et al v. Kathryn Rae Zehnder Minn. Ct. App. 2025
14 We acknowledge the Minnesota Supreme Court’s statement that “statutorily created immunity should be construed narrowly.”
Kimberly Hamson, et al v. The Foothills Christian Academy Society of Backus, MN, et al Minn. Ct. App. 2025
Qualified privilege is based on the premise that “statements made in particular contexts or on certain occasions should be encouraged despite the risk that the statements might be defamatory.” (), rev. denied (Minn. May 16, 2023).
Gracelyn Trimble v. Dalvin Cook, Daniel Cragg, et al Minn. Ct. App. 2024
12 (emphasis added) (quoting Restatement (Second) of Torts § 584, at 243 (Am.
Gary H Burdorf, et al v. Michael Miller Minn. Ct. App. 2024
In short, “[q]ualified privilege applies when a court determines that statements made in particular contexts or on certain occasions should be encouraged despite the risk that the statement might be defamatory.” (quotation omitted).
Karen K. Osowski v. Edie Harer Minn. Ct. App. 2023
“One who makes a defamatory statement will not be held liable if the statement is published under circumstances that make it qualifiedly privileged and if the privilege is not abused.”
Christopher Abdul-Haqq, et al v. David LaLiberte, et al Minn. Ct. App. 2023
Emily Anick v. Frank Bonsante Minn. Ct. App. 2022
based upon a reasonable or probable cause.” (quotation omitted).
Mariam Aromashodu v. Swarovski North America Limited, et al., Airport Retail Group, LLC, et al Minn. Ct. App. 2022
Shanon Renee Harper, DNP, NP v. Dr. Jennifer Tessmer-Tuck, et al Minn. Ct. App. 2022
Steven Dahl v. Pamela Quinn Minn. Ct. App. 2020
2 The parties and the district court sometimes use the term “absolute immunity,” but caselaw refers to this concept as “absolute privilege.” The Minnesota Supreme Court has stated that absolute privilege is different than an immunity and is likely sometimes referred to as an immunity because “it has the effect of making the publisher of a defamatory statement immune from suit.”
Ryan Larson, Minn. 2020
Samuel Zean, Eunice Zean v. Mark Reveling, et al Minn. Ct. App. 2020
If 7 a qualified privilege applies to the statement, then the plaintiff bears the burden of proving that the “privilege was abused because the defamatory statements were made with malice.”
Maethner v. Someplace Safe, Inc. 929 N.W.2d 868 Minn. 2019
Maethner v. Someplace Safe, Inc. 929 N.W.2d 868 Minn. 2019
" Bol v. Cole , , 149 (Minn. 1997) (quoting Stuempges v. Parke, Davis & Co. , , 256-57 (Minn. 1980) ).
Samuel Zean v. Mary T. Inc., et al. Respondents Minn. Ct. App. 2019
Ashlee Kay Sames v. Scott County, et al Minn. Ct. App. 2019
In order to be protected by a qualified privilege, “ [a] statement must be made in good faith and must be made upon a proper occasion, from a proper motive, and must be based upon reasonable or probable cause.” (quotation omitted).
Sumi Mukherjee v. Lisa Vipperman Minn. Ct. App. 2018
Bol v. Cole , d 143, 149 (Minn. 1997).
Hollis J. Larson v. The Minnesota Department of Human Services, et al Minn. Ct. App. 2018
B. Qualified Privilege “Qualified privilege applies when a court determines that statements made in particular contexts or on certain occasions should be encourag ed despite the risk that the statements might be defamatory.” Bol v. Cole , (quotation omitted).
Robert P. Ivers v. Cub Foods Minn. Ct. App. 2018
Mark Molitor v. Stephanie Molitor Minn. Ct. App. 2017
d 143, 146 (Minn. 1997).
Michael Harlow v. State of Minnesota Department of Human Services, et al Minn. Ct. App. 2016
Michael Harlow v. State of Minnesota Department of Human Services, et al Minn. Ct. App. 2016
“One who makes a defamatory statement will not be held liable if the statement is published under circumstances that make it qualifiedly privileged and if the privilege is not abused.”
Jerry Expose, Jr. v. Thad Wilderson & Associates, P.A., Nina Mattson 889 N.W.2d 279 Minn. 2016
Jerry Expose, Jr. v. Thad Wilderson & Associates, P.A., Nina Mattson 889 N.W.2d 279 Minn. 2016
Melinda M. Binkley, Trustee on behalf of the heirs and next of kin of Kirk T. Lloyd, II … 877 N.W.2d 547 Minn. 2016
James L. Mandel v. Multiband Corporation, et al Minn. Ct. App. 2016
James L. Mandel v. Multiband Corporation, et al Minn. Ct. App. 2016
S.F. v. Clay County, et al Minn. Ct. App. 2014
S.F. v. Clay County, et al Minn. Ct. App. 2014
the supreme court considered the release of a child-abuse report by a psychologist.
J.E.B. v. Danks 785 N.W.2d 741 Minn. 2010
J.E.B. v. Danks 785 N.W.2d 741 Minn. 2010
(noting that use of exaggerated language can support inference of actual malice).
Nexus v. Swift 785 N.W.2d 771 Minn. Ct. App. 2010
Nexus v. Swift 785 N.W.2d 771 Minn. Ct. App. 2010
-48 (Minn.1997) (absolute privilege); Jadwin, d at 481 (qualified privilege).
Bahr v. Boise Cascade Corp. 766 N.W.2d 910 Minn. 2009
Bahr v. Boise Cascade Corp. 766 N.W.2d 910 Minn. 2009
Mahoney & Hagberg v. Newgard 729 N.W.2d 302 Minn. 2007
Mahoney & Hagberg v. Newgard 729 N.W.2d 302 Minn. 2007
This court will not apply absolute privilege unless the “administration of justice requires complete immunity from being called to account for language used.” Id.; (“For absolute privilege to apply, the public interest served must be one of paramount importance, such that it is entitled to protection even at the expense of failing to compensate harm to the defamed person’s reputation.”).
In Re the Estate of Bonde 694 N.W.2d 74 Minn. Ct. App. 2005
In Re the Estate of Bonde 694 N.W.2d 74 Minn. Ct. App. 2005
Minnwest Bank Central v. Flagship Properties LLC 689 N.W.2d 295 Minn. Ct. App. 2004
Minnwest Bank Central v. Flagship Properties LLC 689 N.W.2d 295 Minn. Ct. App. 2004
Edward Kraemer & Sons, Inc. v. Ashbach Construction Co. 608 N.W.2d 559 Minn. Ct. App. 2000
Kuelbs v. Williams 609 N.W.2d 10 Minn. Ct. App. 2000
Kuelbs v. Williams 609 N.W.2d 10 Minn. Ct. App. 2000
Based on the Minnesota Supreme Court’s we conclude respondents are entitled to a qualified privilege.
Edward Kraemer & Sons, Inc. v. Ashbach Construction Co. 608 N.W.2d 559 Minn. Ct. App. 2000
LeGro v. Saterdalen 607 N.W.2d 173 Minn. Ct. App. 2000
LeGro v. Saterdalen 607 N.W.2d 173 Minn. Ct. App. 2000
Simpson v. American Family Insurance Co. 603 N.W.2d 860 Minn. Ct. App. 2000