Plаintiffs appeal from a Macomb Circuit Court order granting summary disposition to defendant Joan Carpenter undеr MCR 2.116(C) (7). Plaintiffs argue that the trial court erréd in granting summary disposition on the basis of absolute privilege. We affirm.
i
Defendant is а Sterling Heights City Council member. Plaintiff William Froling, Sr. is a developer who sought to rezone a parcel of land located within the city. The city council voted to approve the rezoning petition on June 7, 1988. Defendant votеd against it. However, a second vote was required pursuant to the Sterling Heights Charter and was held on July 19, 1988. The rezoning рetition was denied on that date when it failed to receive approval by a two-thirds majority.
Plaintiffs’ complaint alleges that on July 20, 1988, at the request of Mayor Pro-Tern Stephen Rice, Mayor Jean DiReeze Gush schedulеd a special meeting of the city council for July 25, 1988. The purpose of the meeting was to consider aр *370 pointments to various Sterling Heights’ committees and commissions. During that televised meeting, defendant indicated:
I had thе pleasure of being at the Goodfellows Golf Outing that Thursday evening. I also, had the experience of having Mr. Froling ask me to have a drink, which I sat down and did and he proceeded to tell me that he asked Jean Gush to call this meeting because they had to get rid of Rudy Pale and Jack Sisinger on the Planning Commission. He asked us to call the meeting to get rid of those people, had to get the jerks out of office and put people in therе that would not embarrass this council and I think that the public should know that. Thank you.
It was postponed for thirty days, Steve [Rice], you would have been back by then. Why do we have to call a special meeting when it was postpоned for thirty days? The meeting was called right after Mr. Froling spoke.
Mr. Froling talked to you [Gush] after the meeting. He told me.
Plаintiffs’ complaint contained three counts: defamation, intentional infliction of emotional distress and cоnspiracy to deny plaintiffs’ rezoning request. The trial court granted summary disposition to defendant on Counts i and ii, defamation and intentional infliction of emotional distress, ruling that the claims were barred by absolute privilege. MCR 2.116(C)(7). A year later, the court granted defendant’s motion for summary disposition as to Count iii, conspiracy, under MCR 2.116(0(10). Count iii also сontained an intentional infliction of emotional distress claim. The court dismissed the emotional distress claim, ruling that plaintiffs did not allege facts sufficient to demon *371 strate severe emotional distress. Plaintiffs do not challenge the ruling.
n
Plaintiffs argue that the trial court erred in applying the absolute privilege doctrine. They assert that the сourt was required to ascertain whether defendant’s statements were made while carrying out her official duties. If she were acting outside the scope of her duties, the privilege would not apply.
The doctrine of absolute privilege is narrow.
Raymond v Croll,
The communication at issue here was made by a city council member during the сourse of legislative proceedings. The absolute privilege for legislative bodies extends to subordinate bodies, such as a city council. See
Gidday v Wakefield,
It is clear that the statements here were made while dеfendant was carrying out her official duties in her legislative capacity. See Domestic Linen, supra; Gidday, supra. Defendant’s duties as a city council member include revealing her belief that: 1) the mayor and plaintiffs colluded to call a special meeting; and 2) plaintiffs and the mayor were conspiring to have certain committee appointments made. The fact that defendant’s statements were not made during a debate on an agenda item or in respоnse to comments by another person does not defeat the privilege. See Chonich, 466. We conclude that thе trial court did not err in ruling that plaintiffs’ defamation claim was barred by defendant’s absolute privilege.
in
The doctrine of absolute privilege may not apply to intentional infliction of emotional distress claims. See Domestic Linen, 837. The triаl court dismissed plaintiffs’ intentional infliction of emotional distress claim (Count ii) based on privilege. On appeal, plaintiffs do not distinguish between the defamation claim (Count i) and the intentional infliction of emotional distress claim (Count n) for purposes of applying the absolute privilege doctrine. In fact, both claims arose from defendant’s *373 allegedly defamatory statements. Plaintiffs did not appeal from the trial court’s dismissal of the intentionаl infliction of emotional distress claim contained in Count in.
We conclude that plaintiffs abandoned this issue by failing to argue in their appellate brief the merits of their allegation of error caused by the dismissal of Count n. Seе
People v Kent,
The trial court did not err in granting defendant’s motion for summary disposition.
Affirmed.