Modzelewski's Towing & Storage, Inc. v. Government Employees Ins. Co.

Syllabus

The plaintiffs appealed from the trial court's judgment granting, on juris- dictional grounds, motions to dismiss filed by the defendants in their action asserting, inter alia, a claim of defamation through slander. They claimed that the court improperly concluded that the complaints filed against them by the defendants with the Department of Motor Vehicles pursuant to state regulation (§ 14-63-45b) were entitled to absolute immunity under the litiga- tion privilege. Held: The trial court properly granted the defendants' motions to dismiss, as pub- lic policy supports the application of the litigation privilege to complaints filed with the Department of Motor Vehicles pursuant to § 14-63-45b of the regulations. Argued October 23, 2025—officially released March 24, 2026