—applying absolute privilege to communications before the Chicago Board of Election Commissioners because it is a quasi-judicial body

If the defendant's letter had set in motion the bar's trial procedure and he had been called before the trial committee to testify as a witness the quasi-judicial character of the proceeding would warrant the application of the rule of absolute privilege.

Statements made before various administrative boards and commissions have been recognized as absolutely privileged.

The breadth of this privilege is illustrated by the facts that it has been extended to quasi-judicial proceedings

In England the rule on privilege is that any statement made in a pleading is absolutely privileged regardless of the fact that it may have no relevancy to the issue

—stating that the "innuendo is to connect the defamatory matter with other facts" and "it cannot enlarge or restrict the natural meaning of the words

A candidate 16A qualified privilege is generally granted to a person making defamatory and false statement concerning a candidate for an appointive office to the appointing power.

These allegations, of course, did not make the words libelous per se if they were not such standing alone.

However, the defendants do not cite, nor has our research revealed, any Illinois case that has found a quasi-judicial proceeding or a "necessarily preliminary" step towards one in a proceeding before a private entity (which the parties concede Northwestern is) rather than one involving a governmental agency or another type of State actor.

The innuendo is irrelevant to the issue of whether the words are actionable per se, since words not actionable per se cannot be made so by innuendo.

[CITATION] Law of defamation

[PDF] UMKC School of Law Institutional Repositor y