Carradine v. Minnesota
Minnesota Supreme Court
511 N.W.2d 733 (1994)
State trooper Patrick Chase (defendant) arrested actor and racecar driver Robert Carradine (plaintiff), and in his arrest report and to jail personnel, prosecutors, and a reporter, described conduct including speeding, reckless driving, fleeing an officer, and impersonating an officer — statements that spread through multiple news outlets. Carradine sued Chase and the state for defamation and other claims; the trial court granted summary judgment for the defendants on all but three claims, including denying summary judgment on the defamation claim, and the court of appeals affirmed that Chase lacked absolute immunity for statements in the arrest report and to the press, prompting the state's petition for Minnesota Supreme Court review.
Whether an executive officer may enjoy absolute immunity from defamation liability.