Case Explained: ZIA CHISHTI AND SARAH POBERESKIN v. TATIANA SPOTTISWOODE

Court: United States Court of Appeals for the District of Columbia Circuit

Filed: 2026-07-07

The D.C. Circuit affirmed the district court’s dismissal with prejudice of an amended complaint seeking damages for defamation, false light, breach of contract, and related torts arising from Tatiana Spottiswoode’s congressional testimony and subsequent media statements regarding her sexual harassment allegations against Zia Chishti. The court held that Chishti’s defamation and false light claims based on Spottiswoode’s testimony before the House Judiciary Committee are barred by the District of Columbia common law absolute privilege for witnesses communicating information to a legislative body under Restatement (Second) of Torts § 590A, as the statements had a relation to the proceeding and were made with an intent to inform the legislature, regardless of alleged bad faith or self-serving motives. The court further ruled that Spottiswoode’s and her attorney’s post-hearing statements to the news media and on social media, as well as republications of the testimony, are protected opinions under the First Amendment because they are not reasonably susceptible of being proved true or false, and are additionally shielded by the fair reporting privilege for accurate reports of official proceedings. The breach of contract claim regarding the disclosure of an arbitral award to Congress was also dismissed because the legislative privilege extends to such communications to ensure witnesses can address the government without fear of liability, consistent with the purpose of the privilege under D.C. law. Finally, the court dismissed Chishti’s remaining tort claims as duplicative of the barred defamation claims and his conspiracy and loss of consortium claims for failing to state underlying torts. The practical consequence is that the plaintiffs’ appeal is denied, the dismissal stands, and the case is closed with no further opportunity to amend the complaint.

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