## Facts

- Fiona Parnigoni taught at St. Columba’s Nursery School from 2001 to 2008.
- During her employment, her then-fiancé (later husband), David Parnigoni, was convicted of indecent exposure to a minor; Fiona disclosed the conviction to school leadership.
- After Fiona and David had a child (Andrew), they sought to enroll him at the school; the school allegedly agreed subject to restrictions that David would not enter the premises or pick up Andrew.
- Weeks later, school and church leaders allegedly said they needed to inform the school community that Fiona had married a “sex offender” and suggested the situation was Fiona’s fault.
- Fiona offered to withdraw Andrew and resign to prevent broader disclosure.
- The school sent a letter to approximately 3,500 households stating, in substance, that Fiona had married a convicted sex offender and that the couple’s son had recently been enrolled.
- Plaintiffs alleged the communication caused reputational and emotional harm, contributed to Fiona’s contract non-renewal, and damaged her future employment prospects.

## Issues

1. Whether the amended complaint plausibly alleged defamation where the communication’s literal factual kernel was true but allegedly carried a stigmatizing implication about Fiona’s fitness and safety as a teacher.
2. Whether plaintiffs plausibly alleged false light based on mass dissemination that allegedly portrayed Fiona as responsible for exposing children to danger.
3. Whether plaintiffs stated a public-disclosure-of-private-facts claim where the disclosed conviction was a matter of public record.
4. Whether Fiona plausibly alleged promissory estoppel and intentional interference with prospective economic advantage based on alleged assurances and foreseeable professional harm.
5. Whether IIED, negligent misrepresentation, loss of consortium, and claims asserted on behalf of the child were adequately pleaded.

## Decision

- The court granted in part and denied in part defendants’ Rule 12(b)(6) motion.
- Defamation (Fiona): motion denied.
- False light (Fiona): motion denied.
- Public disclosure of private facts: motion granted.
- Promissory estoppel (Fiona): motion denied.
- Intentional interference with prospective economic advantage (Fiona): motion denied.
- IIED: motion granted.
- Negligent misrepresentation: motion granted.
- Loss of consortium: motion granted.
- All claims asserted on behalf of Andrew Parnigoni: motion granted.

## Legal Principles

- Under Rule 12(b)(6), a complaint must allege enough factual matter to make entitlement to relief plausible, not merely conclusory labels.
- Defamation may be plausibly pleaded where a publication, though factually accurate in part, is alleged to convey a defamatory “gist” or implication that harms reputation (including implications about professional fitness).
- False light may lie where widely disseminated statements or implications place a person before the public in a highly offensive and materially false way.
- Public disclosure of private facts generally does not apply to information drawn from public records or otherwise not legally “private.”
- IIED requires allegations of conduct that is extreme and outrageous; mere insensitivity or harshness is insufficient.
- Promissory estoppel requires a clear promise, reasonable reliance, and detriment; plausibility can be met by allegations of assurances tied to employment-related expectations and ensuing harm.
- Intentional interference with prospective economic advantage requires an identifiable expectancy and intentional, unjustified interference plausibly causing economic harm.
- Claims by a minor require allegations satisfying each tort’s elements as to the child, including an actionable harm to the child’s own legally cognizable reputation or interests.

## Conclusion

The court allowed Fiona Parnigoni’s defamation, false-light, promissory-estoppel, and prospective-economic-advantage interference claims to proceed based on alleged stigmatizing implications from a mass letter to the school community, while dismissing private-facts, IIED, negligent-misrepresentation, consortium, and the child’s claims for failure to satisfy the required elements at the pleading stage.


Parnigoni v. St. Columba’s Nursery Sch., 681 F. Supp. 2d 1 (D.D.C. 2010)