Lasater v. Vidahl, 979 N.E.2d 828

Lasater sued Vidahl for placing her in false light arising from Vidahl's police reports and a letter to a magistrate.
Vidahl sought a civil protection order, which the domestic relations court granted, restricting Lasater within 500 feet.
Vidahl filed incident reports with Akron Police alleging Lasater violated the protection order, leading to Lasater's arrests and custodial time before release; charges were dismissed.
Vidahl filed a second police report alleging violations, resulting in more arrests; municipal court later dismissed the charges on prosecutor's advice.
Vidahl moved the domestic relations court to hold Lasater in contempt; the order was amended to permit Lasater to visit certain relatives' homes.
Lasater sued Vidahl for false light; the trial court granted dismissal, holding Vidahl's letter to the magistrate absolute privilege and finding insufficient publicity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Vidahl's statements are absolutely privileged.	Lasater claims no absolute privilege covers the communications.	Vidahl's statements are protected under absolute privilege as part of judicial/public proceedings.	Yes; statements to police and to the magistrate are absolutely privileged.

M.J. DiCorpo Inc. v. Sweeney, 69 Ohio St.3d 497 (1994) (absolute privilege for statements bearing relation to reported criminal activity)
Welling v. Weinfeld, 113 Ohio St.3d 464 (2007) (false light requires pleading publicity)
Hecht v. Levin, 66 Ohio St.3d 458 (1993) (recognizes judicial proceedings privilege concept)