Background
Zia Chishti, a former executive, and his wife sued Tatiana Spottiswoode and others following an arbitration where Spottiswoode prevailed on harassment claims. Spottiswoode testified before Congress about the case, and Chishti alleged her testimony and subsequent media statements were defamatory and breached arbitration protective orders. The district court dismissed the amended complaint with prejudice.
The court’s reasoning
The court applied District of Columbia law and found that Spottiswoode’s statements to Congress were absolutely privileged under the common law privilege for witnesses communicating with a legislative body. The court determined that her post-hearing statements to the media were protected opinions or covered by the fair reporting privilege. Additionally, the court held that the legislative privilege extended to the breach of contract claim regarding the disclosure of the arbitration award to Congress, as the disclosure was necessary to defend against accusations made during the legislative proceeding.
Succinctly put, Zia Chishti’s defamation and false light claims based on Tatiana Spottiswoode’s testimony before Congress, as well as Chishti’s related breach of contract claim, are protected under District of Columbia law by a common law privilege for witnesses communicating information to a legislative body and therefore not actionable.
What it means going forward
The ruling reinforces the scope of legislative privilege in the District of Columbia, extending it to breach of contract claims arising from disclosures made to Congress in response to legislative inquiries, and clarifies that media statements following congressional testimony are often protected as opinion.