A psychiatrist filed a complaint against his hospital department chair for allegedly falsifying department meeting minutes. A month later, the psychiatrist was reported "unfit" to the state director in charge of investigating physician complaints. The psychiatrist was evaluated and found to be paranoid and his license to practice was suspended. The psychiatrist sued both the director and evaluating psychiatrist for defamation. The suit was dismissed due to insufficient evidence of "actual malice" and the psychiatrist appealed.

The Appellate Court of Connecticut affirmed the trial court opinion and found that although there were findings that there was not enough evidence for the evaluating psychiatrist to reach the "paranoia" diagnosis, the "failure to undertake adequate investigation is not dispositive of actual malice." Thus, without specifically pleading facts which showed he purposefully avoided the truth, or filed a report he knew was false, there was not enough to overcome the evaluating psychiatrist's immunity defense.