"Prime" --but wrong-- suspect cannot sue for defamation
Plaintiff Wilson sued the Sparrow Health System and the Lansing Athletic Club for defamation. As the Club was closing on a night in August of 2006, a man exposed himself to two lifeguards at the pool. They reported the incident, and the Club showed them file photographs of the 16 male "members" who had checked in that evening. [We don't know how literally to interpret that statement in the opinion.] The Plaintiff was incorrectly identified as the perpetrator and a "prime suspect" until another man confessed to this and a second, similar incident. In the interim, the Club distributed a new set of procedures to follow in the event of similar incidents and identified the Plaintiff as the "prime suspect." When the Plaintiff was cleared of the charges, he sued for defamation. The Court of Appeals upheld the dismissal of his claim, pointing out that the reports to the police were subject to complete immunity, having been made in good faith. Further, the subsequent identification of the Plaintiff as the "prime suspect" in the previous incident was not defamatory because it was true.