Mulder v. Pilot Air Freight

Mulder v. Pilot Air Freight (2004) 32 Cal.4th 384, concerned communications to the police department. In Mulder, supra, 32 Cal.4th 384, one of the defendants contacted the police and reported that the plaintiff possessed a stolen flight recorder. (Id. at p. 386.) After the police detained, handcuffed, and searched the plaintiff, the plaintiff sued for false imprisonment and intentional infliction of emotional distress. (Ibid.) The court held that the plaintiff's claims were barred by the absolute privilege under section 47, subdivision (b). The court explained that this privilege applies "to a communication ' "concerning possible wrongdoing, made to an official governmental agency such as a local police department, . . . if the communication is designed to prompt action by that entity. . . ." ' " (Mulder, supra, at p. 387, citing Hagberg, supra, 32 Cal.4th at p. 364.)