§ 6.4.5.1 PUBLICATION AND INTRACORPORATE COMMUNICATIONS

• Jurisdiction: Arizona

§ 6.4.5.1 Publication and Intracorporate Communications. One issue that may arise involves statements made within a corporation that are believed to be defamatory. Some states have found that there is no corporate liability for communications made by one co-employee to another, reasoning that such communications are nothing more than "the corporation, through its agents, talking to itself."¹⁰⁹ The reasoning used in such cases is that there was no publication by the corporation to any third person.¹¹⁰ Other courts have expressly refused to adopt the intracorporate communication doctrine.¹¹¹

Arizona Courts, following the Restatement,¹¹² have specifically decided that defamation suits based on intracorporate communications can proceed, subject to a qualified privilege.¹¹³

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Notes:

^[109] Halsell v. Kimberly-Clark Corp., 683 F.2d 285...