Hospital and director of medical education are immune from liability for defamation

Steven Woodward was a fifth-year medical student at American University of Antigua when he ws placed in a clinical rotation at Trinity Health-Michigan.  An administrator  at St. Joseph Mercy Hospital send a memorandum to AUA describing Woodward's  "lack of professionalism and poor communication skills."   In response AUA dismissed Woodward from its program and he sued for libel per se, intentional infliction of emotional distress and tortious interference with a contractual relationship. 

The Court upheld the dismissal of Woodward's case against the school, pointing to an established deference to the academic judgment of academic professionals in making genuine academic decisions.    It also upheld the dismissal of the tort claim against Trinity, finding that the Trinity administrator enjoyed qualified privilege and  immunity for her good faith evaluation of Woodward's performance.  Absent evidence of actual malice, the plaintiff cannot sue for these "unpublished" comments  that are inherent in the parties' relationship.