context: Applying Iowa law to the allegations of Count II of the counterclaim, we find that Asay was not entitled to an absolute privilege on the basis of the pleadings. In determining whether an occasion is absolutely privileged, the pivotal factor is frequently to whom the matter is published. Publication to the news media is not ordinarily sufficiently related to a judicial proceeding to constitute a privileged occasion.
citation_a.signal: no signal
citation_a.parenthetical: attorney's statement to editor of newspaper regarding his criminal client's defense
citation_a.sentence: Barto v. Felix, 250 Pa.Super. 262, 378 A.2d 927 (1977) (statements made at press conference); Bradley v. Hartford Accident & Indemnity Co., 30 Cal.App.3d 818, 106 Cal.Rptr. 718 (1973) (statements made to newspaper and television reporters regarding documents that were filed with the court for the sole purpose of having defamatory statements contained therein disseminated to the media); Kennedy v. Cannon, 229 Md. 92, 182 A.2d 54 (1962) (attorney’s statement to editor of newspaper regarding his criminal client’s defense).
citation_b.signal: cf.
citation_b.parenthetical: federal judge delivering allegedly libelous statements to a newspaper editor not immune from liability in state libel action.
citation_b.sentence: Cf. Chandler v. O’Bryan, 445 F.2d 1045 (10th Cir. 1971) cert. denied, 405 U.S. 964, 92 S.Ct. 1176, 31 L.Ed.2d 241 (1972) (federal judge delivering allegedly libelous statements to a newspaper editor not immune from liability in state libel action.)