Supreme Court of North Carolina

Bouvier v. Porter

May 23, 2024

Summary

The Court held that the absolute privilege for statements made in judicial or quasi-judicial proceedings protects everyone involved in any aspect of an election protest, including individuals who research, prepare, approve, facilitate, direct, or file the protest but do not attend the hearing. Because the challenged statements were made during the course of quasi-judicial election-protest proceedings and were relevant and pertinent to those proceedings, defendants were entitled to summary judgment on the defamation and derivative civil-conspiracy claims. The Court reversed and remanded for dismissal with prejudice.