Thompson v Bridges [1925] 273 SW 529
(Court of Appeals of Kentucky)
Slander; conspiracy to injure
(288 words)
Facts
The appellant was a high school teacher and principal of his school. In 1922, a bitter campaign was fought for trusteeships at Princeton schools, whereby the appellant’s opponents were elected. Several months later, the respondents organised a parent-teacher association of the schools in question with the purpose of investigating the appellant’s conduct, especially his relationships with older girls in his school. At the association’s first meeting, the appellant’s supporters were not allowed to speak on his behalf. At a later meeting, the respondents made direct accusations regarding the appellant’s morality and his conduct with the older girls in his school. These remarks made the appellant appear unfit for his role as principal and discredited his standing as a teacher.
Issues
Despite the prima facie slanderous nature of the comments about the appellant, the respondents argued that their statements were prima facie privileged. Thus, the presumed malice coming from a prima facie slanderous statement was rebutted by the prima facie privilege – as a result, it was for the appellant to show actual malice.
Decision/Outcome
The Court agreed that the slanderous statements were made in circumstances giving rise to qualified privilege – they were said at a parent-teacher meeting designed to uncover and solve problems in schools, and as the appellants was the principal of a school, discussions regarding his fitness or morality were rightly seen as privileged. The respondents were thus right in arguing that the presumed malice of prima facie slanderous statements can be rebutted by qualified privilege. However, if the appellant is then able to show actual malice, the privilege disappears. In this case, the appellant could prove that the allegations made against him were false – and malice could be inferred from the falsity of the statements.
Updated 20 March 2026
This article summarises a 1925 decision of the Court of Appeals of Kentucky, a US jurisdiction. It is presented as a case study in defamation principles, specifically qualified privilege and malice in the context of slander. As a historical US authority, it has no binding effect in English and Welsh law and is unlikely to be cited in UK proceedings. The core principles illustrated — that qualified privilege can rebut presumed malice, but that actual malice defeats the privilege — remain consistent with the general approach in English defamation law, now governed primarily by the Defamation Act 2013. Readers should note, however, that English law has developed significantly in this area: the 2013 Act reformed the test for malice and privilege in a number of respects, and the case should be read only as a general conceptual illustration rather than as an authority on current English law. The citation and case details appear consistent with the reported decision.
