In Villarini v. Iowa City Community School District, the Iowa Supreme Court examined the dismissal of claims of wrongful discharge in violation of public policy and defamation that were brought by a former high school tennis coach. The Iowa Supreme Court affirmed the decisions of both the Iowa Court of Appeals and the Johnson County District Court in a unanimous opinion written by Chief Justice Christensen.

Amie Villarini began working as Iowa City West High School’s girls’ varsity tennis coach in 2013. Upon the conclusion of the 2021 season, complaints against Villarini were brought to the school’s athletic director by several tennis players and parents of team members. These individuals asserted Villarini allegedly “inappropriately touched players, engaged in favoritism, lied to players, made insensitive or belittling remarks to players, ignored players’ mental health, retaliated against players, and asked players to miss religious services.” Though Iowa City Community School District (“ICCSD”) did not find Villarini bullied, harassed, or inappropriately touched team members, ICCSD advised Villarini to avoid touching team members moving forward.

Previous tennis team members came to the ICCSD board of directors meeting on April 12, 2022. Though the former members did not mention Villarini by name, they voiced “concerns with the investigation and their disappointment with its results” during the public-comment portion of the meeting. Following the ICCSD board of directors meeting, Villarini made a Facebook post that primarily honored her late grandmother but also stated, “I’m doing my best to ‘turn the page.’ And to pray for those who are against me and who spread hate and false judgments.’” Villarini was put on administrative leave with pay for the remainder of her contract on the day following the board of directors meeting.

An unedited, full video recording of the board of directors meeting was uploaded to the board’s YouTube account. ICCSD was unwilling to edit or remove the video when Villarini and her attorney asked ICCSD take down the recording, include a disclaimer, or redact comments.

Alleging wrongful termination in violation of public policy and defamation, Villarini sued ICCSD. The district court granted ICCSD’s motion for summary judgment, and the court of appeals affirmed this ruling.

As to the defamation claim, the only issue examined by the Iowa Supreme Court was whether the district court correctly found fair-report privilege applied. The Iowa Supreme Court officially adopted the definition of fair-report privilege given in the Restatement (Second) of Torts, stating this “privilege protects [t]he publication of defamatory matter concerning another in a report of an official action or proceeding or of a meeting open to the public that deals with a matter of public concern . . . if the report is accurate and complete or a fair abridgement of the occurrence reported.” However, this privilege does not apply if the report of what occurred is inaccurate.

The Court determined ICCSD’s posting of the recording was protected by the fair-report privilege because the recording was “accurate and completely unabridged.” Because the recording allowed those unable to come to the meeting to view the proceedings, the Court also asserted that recognizing fair-report privilege in these circumstances advances policy objectives of Iowa’s open-meeting laws. Further, the Court observed that meeting record keeping is an obligation of ICCSD. In sharing such a recording, ICCSD is fulfilling this obligation. Consequently, the Court held that the district court acted properly in dismissing the defamation claim.

The Court then affirmed the dismissal of Villarini’s claim of wrongful termination in violation of public policy. In support of its holding, the Court asserted Villarini did not point to “a clearly defined and well-recognized public policy that ICCSD violated,” noting that such a public policy would have to originate in a constitutional provision, statutory law, or administrative regulations.

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