Valencia v. Citibank International
Cases that cite this one
27 later published cases cite this decision. The 25 that cite it most often are listed here.
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- Turner v. Wells (United States District Court for the Southern District of Florida 2016)
- Richard Keith Alan, II v. Wells Fargo Bank, N.A. (11th Cir. 2015)
- Kingland Estates, Ltd. v. Davis (Fla. Dist. Ct. App. 2015)
- Nitv, L.L.C. v. Baker (Fla. Dist. Ct. App. 2011)
- Matthew Bush v. Raytheon Company (11th Cir. 2010)
- Mary White v. School Board Hillsborough County (11th Cir. 2009)
- Krinsky v. Doe 6 (Cal. Ct. App. 2008)
- Furmanite America, Inc. v. T.D. Williamson, Inc. (United States District Court for the Middle District of Florida 2007)
- Kalmanson v. Nofziger (In re Nofziger) (United States Bankruptcy Court, M.D. Florida 2006)
- Fortson v. Colangelo (United States District Court for the Southern District of Florida 2006)
- Jarzynka v. St. Thomas University School of Law (United States District Court for the Southern District of Florida 2004)
- Robobar, Inc. v. Hilton International Co. (Fla. Dist. Ct. App. 2004)
- Razner v. Wellington Regional Medical Center, Inc. (Fla. Dist. Ct. App. 2002)
- Bass v. Rivera (Fla. Dist. Ct. App. 2002)
- Thompson v. Orange Lake Country Club, Inc. (United States District Court for the Middle District of Florida 2002)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion
Ines VALENCIA, Appellant,
v.
CITIBANK INTERNATIONAL, a Federal Edge Act corporation, Appellee.
District Court of Appeal of Florida, Third District.
Robert E. Weisberg, Coral Gables, and Karen D. Turner, Tallahassee, for appellant.
Holland & Knight and Daniel S. Pearson and Marilyn J. Holifield and Leon N. Patricios, Miami, for appellee.
Before NESBITT, LEVY, and GODERICH, JJ.
LEVY, Judge.
This is an appeal from an order of dismissal and Final Judgment entered against Ines Valencia ("Valencia") for failure to state a cause of action. We affirm.
Valencia brought suit against Citibank International ("Citibank") alleging defamation and compelled self-defamation. Specifically, Valencia alleged that Citibank's reasons for terminating her were false and that she was compelled to disclose the false reasons for her termination to prospective employers. Citibank filed a motion to dismiss the Complaint. After a hearing, the court dismissed the compelled self-defamation count with prejudice for failure to state a cause of action and dismissed the defamation count without prejudice. Thereafter, Valencia filed a voluntary dismissal as to the defamation count. Valencia appeals the dismissal of the compelled self-defamation count.
To state a cause of action for defamation, in Florida, a plaintiff must allege that (1) the defendant published a false statement (2) about the plaintiff (3) to a third party and (4) that the falsity of the statement caused injury to the plaintiff. Seropian v. Forman, 652 So.2d 490 (Fla. 4th DCA 1995). Valencia asks us to set a precedent and recognize compelled self-defamation as an exception to the publication requirement.
Under the doctrine of compelled self-defamation the publication to a third person is, in essence, eliminated. Under the doctrine, a defendant will be liable for alleged defamatory statements she or he made to the plaintiff in private if the plaintiff is "compelled" to repeat or republish the alleged defamatory statements to a third party. See Lewis v. Equitable Life Assurance Society of the U.S., 389 N.W.2d 876 (Minn. 1986). We hold that Florida law does not provide for an exception to the publication requirement of *331 defamation nor are we prepared to create such an exception.
Affirmed.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.