Robinson v. V. D. (2024)

Citation: Robinson v. V. D. (2024)
Parent Document: Robinson v. V. D. (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-11-26
Original Source: https://www.courtlistener.com/opinion/10282961/robinson-v-v-d/ ↗

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occurring in the course of a judicial or quasi-judicial
          proceeding, including, but not limited to, claims for
          tortious interference, intentional infliction of emotional
          distress, fraud, and violations of [the Connecticut Unfair
          Trade Practices Act (CUTPA), General Statutes § 42-
          110a et seq.]. . . .
             ‘‘The policy underlying the [litigation] privilege is that
          in certain situations the public interest in having people
          speak freely outweighs the risk that individuals will
          occasionally abuse the privilege by making false and
          malicious statements. . . . Participants in a judicial
          process must be able to testify or otherwise take part
          without being hampered by fear of defamation [or other
          retaliatory litigation]. . . . [In] determining whether a
          statement is made in the course of a judicial proceeding
          . . . the court must decide as a matter of law whether
          the [alleged statement is] sufficiently relevant to the
          issues involved in . . . [the] proceeding, so as to qual-
          ify for the privilege. . . . The test for relevancy is gen-
          erous, and judicial proceeding has been defined liber-
          ally to encompass much more than civil litigation or
          criminal trials.’’ (Citations omitted; internal quotation
          marks omitted.) Deutsche Bank AG v. Vik, supra, 349
          Conn. 137–38.
             In deciding whether a person is entitled to absolute
          immunity under the litigation privilege, ‘‘[courts] must
          first determine whether the proceedings [in question]
          were [judicial or quasi-judicial] in nature. The judicial
          proceeding to which [absolute] immunity attaches has
          not been defined very exactly. It includes any hearing
          before a tribunal which performs a judicial function,
          ex parte or otherwise, and whether the hearing is public
          or not. . . . It extends also to the proceedings of many
          administrative officers, such as boards and commis-
          sions, so far as they have powers of discretion in
          applying the law to the facts which are regarded as
          judicial or quasi-judicial, in character.’’ (Emphasis
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