12/4 – In Patterson v. Roe, a defamation and negligence action brought by a former Southwestern Baptist Theological Seminary student, a federal district court clarified the scope of liability for allegedly defamatory statements. The plaintiff, proceeding as Jane Roe, alleges that a donor letter defending former seminary president Paige Patterson contained false statements that damaged her reputation after she reported a sexual assault.

The U.S. District Court for the Eastern District of Texas reaffirmed dismissal of all claims against the seminary, holding that employees involved in preparing the letter acted outside the scope of their employment and that the institution could not be held vicariously liable.
Claims against Patterson individually, however, remain pending in light of intervening state-court rulings clarifying Texas defamation law, including that liability may attach to individuals who supply defamatory content for publication even if they did not author or publish the final statements.