Attorney David Anziska made statements about the Thomas M. Cooley Law School, some of which were posted on the Internet and some of which were alleged in a complaint. Thomas M. Cooley Law School sued Anziska and his firm for the state law claims of defamation, tortious interference with business relations, breach of contract, and false light. Strangely, no allegations of wrong doing were made about my favorite statement by Anziska: “These schools are preying on the blithe ignorance of naive, clueless 22-year-olds who have absolutely no idea what a terrible investment obtaining a JD degree is. Perhaps one of the worst offenders is the Thomas Cooley School of Law, which grossly inflates its post-graduate employment data and salary information.” (Opinion pdf page 2). Looking back at myself as a K through JD, I was definitely naïve and clueless at age 22. That didn’t stop me from going back for my IP LL.M. years later. Silly me.
The district court granted summary judgment in favor of Anziska and the other defendants. The district court determined that Thomas M. Cooley Law School was a limited-purpose public figure and that no reasonable jury could conclude that Anziska published the statements with actual malice. The Sixth Circuit Court of Appeals affirmed.