## Facts

- A private social club serving individuals of Sicilian ancestry bought a former school building in Waterbury, Connecticut and obtained a zoning change allowing it to operate as a social club.
- The club later obtained a liquor license for the premises, despite neighborhood opposition.
- Months after the liquor license issued, a local resident who opposed the club sent a letter to the president of the city’s board of aldermen (copied to other local officials).
- The letter claimed the club had “political connections” and “Mafia connections” enabling “rubber-stamp approval of whatever it wanted.”
- The club sued for libel, alleging the letter falsely associated it with organized crime and corrupt political influence, harming its reputation.

## Issues

1. Whether the letter’s statements accusing the club of “Mafia connections” and corrupt political influence constituted libel per se, permitting recovery without proof of special damages.
2. Whether the statements were absolutely privileged as communications connected to a judicial or quasi-judicial proceeding.

## Decision

- The appellate court reversed summary judgment for the defendant and remanded for further proceedings.
- The court held the statements were libel per se because their defamatory meaning was apparent on their face and imputed criminal and corrupt conduct.
- The court held absolute privilege did not apply because the letter was not made in the course of a pending judicial or quasi-judicial proceeding.

## Legal Principles

- Libel per se is written defamation whose defamatory meaning is apparent from the words themselves and is actionable without proof of actual or special damages.
- When a publication is libelous per se, injury to reputation is conclusively presumed, allowing recovery of general damages for reputational harm and resulting humiliation and mental suffering.
- Whether a statement is libelous per se is a question of law for the court.
- Absolute privilege for defamatory statements is narrowly confined, generally to legislative and judicial proceedings (and closely related quasi-judicial proceedings).
- A communication sent outside an ongoing judicial or quasi-judicial process—such as a post-approval complaint letter to officials—does not receive absolute privilege.

## Conclusion

The court held that allegations of “Mafia connections” and corrupt political influence in securing government approvals were actionable as libel per se and were not shielded by absolute privilege, requiring further proceedings on damages.


Lega Siciliana Soc. Club, Inc. v. St. Germaine, 77 Conn. App. 846, 825 A.2d 827 (Conn. App. Ct. 2003)