Coghlan v. Beck

Court properly dismissed breach of contract claim which was negated by Plaintiffs' verified allegations in complaint and attached exhibits. Court properly dismissed claim of libel per se and slander per se as factual allegations were conclusory and statements at issue were not defamatory per se and were subject to a qualified privilege that Plaintiffs failed to overcome or were subject to an innocent construction. Court properly dismissed claim of civil conspiracy as Plaintiffs failed to properly allege underlying tort, and because factual allegations were conclusory. (HOFFMAN and CUNNINGHAM, concurring.)