Chamberlain v. Mathis
In Chamberlain v. Mathis, 151 Ariz. 551, 554, 729 P.2d 905, 908 (1986), the Arizona Supreme Court established that, as a general rule, state executive officials are entitled only to qualified immunity in defamation actions brought against them in their official capacity. 151 Ariz. at 558, 729 P.2d at 912.
The defendant in Chamberlain was the Director of the Arizona Department of Health Services, an office that the court characterized as "roughly comparable to that of a federal cabinet officer." Id. at 554, 729 P.2d at 908.
The court stated that "the general rule of qualified immunity announced in Grimm v. Ariz. Bd. of Pardons and Paroles, 115 Ariz. 260, 564 P.2d 1227 (1977) should govern the case before us," but it did not foreclose the possibility that absolute immunity might be appropriate for other high-level executive officers.
Indeed, as noted by the majority, supra, P 8, the court recognized that "there may be some government offices that require absolute immunity," but believed that "in the vast majority of cases, qualified immunity will adequately protect state executive officials." Id. at 558, 729 P.2d at 912.