R.H., a high school student at Foothills Christian Academy, a private Christian school in Minnesota, brought a defamation claim against the School and its principal, Blair Ecker, after Ecker made disparaging remarks about her at a student meeting.
R.H. was enrolled at Foothills during the 2021-2022 school year, when the School used a password-protected grading platform to track assignments and student progress. In Spring 2022, a teacher’s aide discovered that several students had gained unauthorized access to a teacher’s account and altered grades. R.H.’s assignments showed irregularities, and when questioned, she admitted to modifying her grades. Before the School completed its investigation, the principal convened a meeting of students and staff to discuss the cheating allegations. R.H. did not attend because her parents had already withdrawn her from the School, but approximately 17 students and faculty members were present.
At the meeting, Ecker referred to R.H. by name and made several remarks that became the basis of the lawsuit. He characterized her as one of the “ringleaders” of the grade-changing scheme and compared her to “a special ed student” with “a poor IQ.” He told students that R.H. had been expelled for cheating and implied she had damaged the School’s integrity. Ecker later acknowledged making these statements.
R.H. filed suit claiming that the remarks were false, defamatory, and repeated throughout the community, causing serious harm to her reputation and emotional well-being. The School moved for summary judgment, asserting that the statements were protected by qualified privilege, a doctrine that shields certain communications made in good faith and for legitimate purposes, such as addressing school discipline. The trial court agreed, finding that although Ecker’s words could be defamatory, his position as principal and the context of the disciplinary meeting afforded him privilege.
The Court of Appeals disagreed, holding that there was sufficient evidence for a jury to decide whether the principal acted in good faith. Under Minnesota law, qualified privilege protects statements made “in good faith, on a proper occasion, with a proper motive, and upon reasonable or probable cause.” R.H. presented evidence suggesting that Ecker’s remarks were not made to serve a legitimate disciplinary purpose but rather to deflect attention from his own failure to control widespread cheating at the School. According to R.H., Ecker had known about grading problems for years and targeted her to protect the School’s reputation after her mother raised the issue with the School’s Board. Viewing the evidence in the light most favorable to R.H., the Court found a genuine factual dispute over whether Ecker’s comments were made in good faith or with an improper motive.
The Court of Appeals also found that the issue of malice, whether Ecker acted with ill will or intent to harm, was a factual question that should be decided by a jury. R.H. offered testimony that Ecker’s statements about her intelligence and supposed expulsion were knowingly false and were made in a public setting intended to humiliate her. A former Foothills trustee supported R.H.’s account, describing long-standing grade manipulation at the School and confirming that multiple students had access to teachers’ passwords. The Court concluded that this evidence, if believed, could demonstrate that Ecker acted deliberately for the purpose of injuring R.H., which would eliminate any privilege that might otherwise apply.
Because the record contained disputed evidence about the principal’s motive and good faith, the Court of Appeals reversed the summary judgment for the School and Ecker and remanded the case for trial.
Hamson v. Foothills Christian Acad. Soc’y of Backus (Oct. 20, 2025, No. A25-0502) 2025 Minn. App. Unpub. LEXIS 817.
Note: This decision underscores that schools must exercise caution when discussing student discipline in public or group settings, especially in California, where students have a constitutional right to privacy.