Liberman v. Gelstein

Liberman (plaintiff), a landlord, sued Gelstein (defendant), a tenants' board member, for slander over two statements: first, Gelstein telling a fellow board member Liberman bribed police to avoid parking tickets, made in an attempt to discover whether the allegation was true, which Gelstein admitted he didn't know was true; second, Gelstein telling a building employee that Liberman had punched him, screamed at his family, called his daughter a slut, and threatened to kill him and his family. The trial court dismissed both claims, finding the first statement qualifiedly privileged with no showing of malice and the second mere rhetorical hyperbole given the parties' contentious history; the Appellate Division affirmed, and Liberman appealed.