Aransas Harbor Terminal R. Co. v. Taber
In Aransas Harbor Terminal R. Co. v. Taber, 235 S.W. 841 (Tex. Com. App. 1921) libelous statements were made in a letter to the Texas Railroad Commission.
The court held that the commission performed judicial functions:
"The power to hear complaints and to investigate them, to summons and compel the attendance of witnesses, to compel persons to testify in transactions being investigated, and the power to render judgment in the matters being investigated are expressly provided by these statutes. What more can any judicial body do?" Id. at 842.
"That communications made in the course of a judicial proceeding are absolutely privileged is no longer a debatable question in this state." Id. at 843.
The court held the letter to the commission was absolutely privileged and no action for libel would lie.