The Ohio Court of Appeals has upheld a lower court's decision to dismiss a defamation lawsuit filed by Kyle Fields against his ex-wife, Lauren Van Ee. The court ruled that Van Ee's statements, made in support of a civil protection order, were protected by absolute privilege. This ruling affects Fields, who claimed that the allegations made against him harmed his reputation and business.
The case, Fields v. Van Ee (CA2025-09-080), revolves around a dispute between the former couple following their divorce in 2015. Fields is a businessman and an active member of the Waynesville community, while Van Ee sought a civil protection order against him in 2022, alleging domestic violence and abuse. The court's ruling is significant as it clarifies the boundaries of defamation law in Ohio, particularly regarding statements made during judicial proceedings.
In September 2022, Van Ee filed a petition for a civil protection order against Fields, claiming he had committed acts of domestic violence and made threats. The court granted a temporary ex parte order, suspending Fields' parenting time with their two children. Van Ee subsequently shared the order and her allegations with the children's school, which led to school personnel learning of the accusations against Fields. Although the domestic relations court later dismissed Van Ee's petition, she did not inform the school of this dismissal.
In response to the allegations, Fields filed a defamation lawsuit against Van Ee in September 2023, claiming her statements were false and made with malicious intent. He sought punitive damages, alleging that the accusations had caused him significant harm. In June 2025, Van Ee filed a motion for judgment on the pleadings, arguing that her statements were protected by absolute privilege because they were made in the context of a judicial proceeding.
The common pleas court agreed with Van Ee, ruling that her statements were protected by absolute privilege. The court stated, "to allow a defamation claim to stand based upon this conduct would undermine the policy supporting [the] litigation [privilege]." The court emphasized that the privilege applies to statements made in judicial proceedings and extends to communications reasonably related to those proceedings.
Judge Matthew R. Byrne, along with Judges Robert A. Hendrickson and Melena S. Siebert, concurred with the ruling. The court noted that Fields' allegations, if false, could be considered defamatory per se, but the absolute privilege afforded to statements made in judicial proceedings protects Van Ee from liability.
The ruling clarifies that in Ohio, once a legal document is filed as part of a judicial proceeding, the absolute privilege generally follows that document wherever it is shared. This means that even if the statements are shared outside the courtroom, they may still be protected if they relate to the judicial process. The court referenced previous cases that support this interpretation, including a Second District Court of Appeals decision that ruled against removing privilege simply because a document was shared with a third party.
The impact of this ruling is significant for individuals involved in legal disputes. It reinforces the idea that parties can communicate necessary information related to court proceedings without fear of facing defamation claims. This ruling may encourage individuals to report allegations of abuse or seek protection orders without the concern of being sued for defamation.
Fields' appeal was denied, and the court affirmed the common pleas court's decision. The ruling sets a precedent in Ohio law regarding the scope of absolute privilege in defamation cases, particularly those involving statements made during judicial proceedings.
Looking ahead, Fields may consider further legal options, but details regarding any potential appeals were not available in the court filing. The case highlights the complexities of defamation law and the protections afforded to individuals making statements in the context of legal proceedings.