Statements made to an “appropriate regulatory agency” are absolutely privileged under Civ. Code 47(b). For this purpose, the Board of Registered Nursing is the appropriate regulatory agency to which to report alleged wrongdoing by RNs. So the defendant hospital’s report regarding plaintiff, a registered nurse, and her allegedly not properly monitoring a patient to whom she had given narcotics, was privileged and could not be the subject of a viable defamation claim even if the report was not made in good faith or was not based on a proper investigation.
California Court of Appeal, Third District (Hoch, J.); February 9, 2017 (published February 27, 2017); 2017 WL 527475