Defamation claim dismissed for lack of specificity in pleadings
Mark Dobronski sued Robert MacDowell and the Southern Michigan Railroad Society, claiming that they had defamed him and failed to comply with an existing settlement agreement including a non-disparagement clause. Dobronski's suit was dismissed by the lower court, after it concluded there was no question of fact with regard to the Defendants' claim that MacDowell was not a director of the Society. Dobronski appealed.
The Court of Appeals upheld the dismissal, relying upon the fact that Dobronski had not adequately pleaded the details of the alleged defamation in his Complaint. It also noted that MacDowell was not a party to the settlement agreement and a corporate director is not normally personally liable for a corporation's breach of an agreement.