Statements to a Police Department

In Bardin v. Lockheed Aeronautical Sys. Co., an employer provided information to the Los Angeles Police Department (LAPD) about a former employee who was applying for a job as a police officer. The employer included information on a complaint filed against the employee regarding drinking on the job. The employee claimed the statements made by her former employer were false and misleading negative information and sued for defamation of character. A California Court of Appeal held that the employer did not defame the former employee because its statements to the LAPD were privileged under California Civil Code section 47(b), which protects communications to a police agency engaged in a background investigation.1

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