William Armstrong v. Karen Thompson, 80 A.3d 177

William Armstrong, a TIGTA special agent, was investigated (criminal and administrative) for unauthorized database access; TIGTA removed his badge/credentials and suspended supervisory authority during the probe.
The U.S. Attorney declined criminal prosecution; TIGTA completed an ROI finding unauthorized access; Armstrong later settled an MSPB appeal by agreeing to a suspension and to resign within 90 days (without admitting liability).
Armstrong accepted a USDA job offer in August 2007; USDA later rescinded the offer after receiving six anonymous letters describing Armstrong as under investigation for criminal and integrity violations.
Karen Thompson (a TIGTA coworker) later admitted she authored the letters; David Sutkus knew of them. Armstrong sued Thompson and Sutkus in D.C. Superior Court asserting defamation, false light, publication of private facts, intentional infliction of emotional distress, and intentional interference with prospective contractual relations.
The Superior Court granted summary judgment for defendants on all claims; the D.C. Court of Appeals affirms the grants as to defamation, false light, publication of private facts, and IIED, but reverses as to intentional interference with prospective contractual relations and remands that claim for trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Defamation — were Thompson's letters false/defamatory?	Armstrong: letters falsely accused him of criminal and integrity violations and caused loss of job.	Thompson: statements were substantially true or nonactionable opinion.	Held: summary judgment for defendants — statements were substantially true or opinion.
False light (invasion of privacy) — publicity and falsity?	Armstrong: letters placed him in an offensive false light.	Thompson: letters were not public (limited recipients) and not false.	Held: summary judgment for defendants — no publicity and no false statements.
Publication of private facts — were disclosed facts private and of public concern?	Armstrong: letters disclosed private TIGTA investigatory information causing humiliation.	Thompson: limited recipients; disclosed matters of legitimate governmental concern.	Held: summary judgment for defendants — publication/publicity element not met.
Intentional interference with prospective employment — wrongful interference?	Armstrong: Thompson knowingly induced USDA to rescind offer; interference was improper given motive and means.	Thompson: transmission of truthful information to government is justified/privileged; conduct was proper.	Held: reversed summary judgment — genuine issues of material fact exist on impropriety/privilege; claim proceeds to jury.

Moldea v. New York Times Co., 15 F.3d 1137 (D.C. Cir.) (substantial truth doctrine; trial court may grant judgment when communication is substantially true)
White v. Fraternal Order of Police, 909 F.2d 512 (D.C. Cir. 1990) (defamation by implication; examine communication in entire context)
Liberty Lobby, Inc. v. Dow Jones & Co., 838 F.2d 1287 (D.C. Cir.) (minor inaccuracies immaterial if gist is substantially true)
Blodgett v. University Club, 930 A.2d 210 (D.C. 2007) (elements of defamation in D.C.)
Foretich v. CBS, Inc., 619 A.2d 48 (D.C. 1993) (recognizing substantial truth as defense to defamation)
Onyeoziri v. Spivok, 44 A.3d 279 (D.C. 2012) (elements and Restatement §767 seven-factor balancing for improper interference)