In Combined Law Enforcement Associations of Texas v. Sheffield, No. 03-13-00105-CV, 2014 WL 411672 (Tex. App.--Austin Jan. 31, 2014, pet. filed), the employer was a labor union that represented law enforcement officers.
Sheffield worked for the union, but was fired, and sued the union for defamation. Id. The allegedly defamatory statements arose from Sheffield's conduct regarding his union-issued computer after he was terminated. Id.
Sheffield complained of five communications he alleged were collectively made to more than seventy police officers and former coworkers:
an email sent by the union's executive director to the union board and staff;
a comment made by the executive director to the president of the Corpus Christi Police Officers Association;
statements union officials made to the Laredo Police Association President;
statements a union lawyer made to an unspecified recipient;
statements the lawyer made to a local District Attorney.
The court of appeals concluded the first three communications were made between members of the union and thus were between individuals who joined together in the union to collectively express, promote, or defend the common interests of police officers.
There was no evidence the remaining two communications were made to members of the union and therefore the Act did not apply to those communications. Id.