## Facts

- Robert Reed Carradine was stopped and arrested by Minnesota State Trooper Patrick Chase while driving to the airport on July 9, 1987.
- Chase reported and later repeated allegations that Carradine engaged in speeding, reckless driving, fleeing an officer, and impersonating an officer.
- Chase communicated the allegations in an arrest report and in statements to jail personnel, prosecutors, and a reporter.
- Carradine was booked, fingerprinted, strip-searched, and held for about 10 hours before release.
- News coverage of the alleged conduct was widespread due to Carradine’s public profile.
- The more serious charges were dropped; Carradine ultimately pleaded guilty only to speeding (a petty misdemeanor).
- Carradine sued Chase and the State asserting multiple federal and state claims, including defamation.
- The district court granted summary judgment for defendants on all federal claims and all state claims except negligent infliction of emotional distress, defamation, and vicarious liability.
- Defendants appealed the denial of summary judgment on the remaining claims, arguing immunity, including absolute privilege; appellate review focused on whether absolute privilege barred the defamation claim.

## Issues

1. Whether a state trooper has absolute privilege (absolute immunity) against defamation liability for statements made in preparing an arrest report.
2. Whether a state trooper has absolute privilege (absolute immunity) against defamation liability for statements made when responding to press inquiries about an arrest.

## Decision

- The Minnesota Supreme Court affirmed the refusal to recognize absolute privilege for the trooper’s statements in the arrest report and to the press.
- The court held the trooper was not absolutely immune from defamation claims arising from those statements.
- The court indicated that any protection for the trooper’s conduct would arise, if at all, under qualified official immunity (and applicable constitutional defamation standards), not absolute immunity.
- The matter proceeded for further litigation under the clarified immunity framework rather than being terminated by an absolute bar.

## Legal Principles

- Absolute privilege in defamation is narrowly limited to contexts such as judicial, legislative, and certain quasi-judicial proceedings, and select high-level executive communications tied to core policy functions.
- Routine law-enforcement reporting and media responses about specific arrests are not placed within Minnesota’s absolute-privilege categories.
- Minnesota official immunity generally protects discretionary acts of public officials from civil liability unless the official acts with malice; this qualified protection may apply to law-enforcement communications depending on the facts.
- For public-figure plaintiffs, defamation liability additionally requires proof of “actual malice” (knowledge of falsity or reckless disregard for truth), which operates alongside state-law immunity doctrines.

## Conclusion

The court declined to extend absolute privilege to a trooper’s arrest-report statements or press comments about an arrest, leaving such speech subject to defamation law and potential qualified official immunity, with public-figure claims also constrained by the constitutional actual-malice requirement.


Carradine v. State, 511 N.W.2d 733 (Minn. 1994)