In Howe v. Detroit Free Press, Inc, 440 Mich. 203; 487 N.W.2d 374 (1992), the defendant newspaper published an article that portrayed the plaintiff as a severely dysfunctional alcoholic. 440 Mich. at 206-207. In the ensuing defamation action, defendants sought discovery of a probation report prepared in connection with the plaintiff's drunk driving conviction. Id., 207. The plaintiff asserted a privilege for probation records under MCL 791.229; MSA 28.2299. Howe, 440 Mich. at 207. The Court rejected the defendants' "automatic waiver" argument, and held that the plaintiffs were "entitled to stand by their claim of statutory privilege and have their interests carefully weighed against those of the defendants without the threat of automatic waiver or sanctions." Id., 224. After balancing these interests, the Court concluded that the "benefit gained by waiving the privilege," (i.e., the defendants' access to information that could support their truth defense) "is far greater than the injury that will inure to the probation officer-probationer relationship." 440 Mich. at 227.