Rainier's Dairies v. Raritan Valley Farms, Inc

In Rainier's Dairies v. Raritan Valley Farms, Inc., 19 N.J. 552, 564, 117 A.2d 889 (1995), a defamation action, the Court observed: "If the policy, which in defamation actions affords an absolute privilege or immunity to statements made in judicial and quasi-judicial proceedings, is really to mean anything then we must not permit its circumvention by affording an almost equally unrestricted action under a different label." The one tort excepted from the reach of the litigation privilege is malicious prosecution, or malicious use of process. Id. at 564-66, 117 A.2d 889. But the Rainier's Court made no such exception in the case of a malicious abuse of process.