Supreme Court of Delaware

Cousins v. Goodier

August 16, 2022

Summary

The Court affirmed dismissal of Cousins’s defamation and tortious-interference claims arising from Goodier’s email criticizing his lawsuit to preserve a high-school mascot. It held that the email addressed a matter of public concern and that its accusations were subjective judgments that were neither objectively verifiable nor based on undisclosed defamatory facts. The Court also held that protected speech, without additional independently wrongful conduct, cannot constitute improper interference with a contract. The Court rejected the lower court’s view that interference requires a sole motive to interfere, but affirmed dismissal on First Amendment grounds.