In Jensen v. Hewlett-Packard Co. (1993) 14 Cal.App.4th 958, the plaintiff sued his employer for defamation based on his supervisor's evaluation of his performance. The trial court granted nonsuit following the employee's opening statement at trial, and a panel of this court affirmed the judgment of nonsuit, stating: "As a prelude to our holding, we express our strong judicial disfavor for libel suits based on communications in employment performance reviews, particularly when, as here, the tort claim appears to be an attempted end run around Foley [v.] Interactive Data Corp. (1988) 47 Cal.3d 654 . . . ." (Id. at p. 964.) The Jensen court further stated: "[U]nless an employer's performance evaluation falsely accuses an employee of criminal conduct, lack of integrity, dishonesty, incompetence or reprehensible personal characteristics or behavior, it cannot support a cause of action for libel. This is true even when the employer's perceptions about an employee's efforts, attitude, performance, potential or worth to the enterprise are objectively wrong and cannot be supported by reference to concrete, provable facts." (Jensen, supra, 14 Cal.App.4th at p. 965.) In Jensen, the plaintiff had stated in the opening statement that his defamation claim was based on the fact he had received two favorable performance evaluations before he received a written evaluation stating that "while his work was adequate in certain respects, he had been the subject of some third party complaints, was not carrying his weight, had a negative attitude in dealing with others, evidenced a lack of direction in his project activities and was unwilling to take responsibility for the projects he oversaw." (Id. at p. 966.) The appellate court concluded, inter alia, nothing in the plaintiff's evaluation could reasonably be interpreted as a false statement of fact and nothing in it suggested he lacked honesty, integrity or the inherent competence, qualification, capability or fitness to do his job, or that he had reprehensible personal characteristics. (Id. at pp. 970-971.) The Court addressed whether a poor performance evaluation by an employer would support a cause of action for defamation by the employee. The Jensen court held: "That unless an employer's performance evaluation falsely accuses an employee of criminal conduct, lack of integrity, dishonesty, incompetence or reprehensible personal characteristics or behavior , it cannot support a cause of action for libel. This is true even when the employer's perceptions about an employee's efforts, attitude, performance, potential or worth to the enterprise are objectively wrong and cannot be supported by reference to concrete, provable facts." (Jensen, supra, 14 Cal.App.4th at p. 965.) The Court found that statements made in an employee's evaluation were not actionable as defamation because the statements were simply one manager's assessment of the employee's work habits, skills, and level of work. ". . . Unless an employer's performance evaluation falsely accuses an employee of criminal conduct, lack of integrity, dishonesty, incompetence or reprehensible personal characteristics or behavior , it cannot support a cause of action for libel. This is true even when the employer's perceptions about an employee's efforts, attitude, performance, potential or worth to the enterprise are objectively wrong and cannot be supported by reference to concrete, provable facts." (Id. at p. 965.) The court found that statements made in an employee's evaluation were not actionable as defamation because the statements were simply one manager's assessment of the employee's work habits, skills, and level of work. ( Id. at pp. 965, 970-971.) ". . . Unless an employer's performance evaluation falsely accuses an employee of criminal conduct, lack of integrity, dishonesty, incompetence or reprehensible personal characteristics or behavior, it cannot support a cause of action for libel. This is true even when the employer's perceptions about an employee's efforts, attitude, performance, potential or worth to the enterprise are objectively wrong and cannot be supported by reference to concrete, provable facts." ( Id. at p. 965.)