Holding that “the First Amendment does not afford a plaintiff the right to run a political campaign that is free from public criticism,” an appellate panel in Rochester has dismissed a defamation action filed by an upstate constable over a letter to the editor written by his boss.
But while the Appellate Division, Fourth Department, threw out Craig Schultz’s defamation claim, it allowed his claims for constructive discharge and violation of his constitutional due process rights to proceed in Schultz v. Town of Wheatfield and Zastrow, 13-01046.
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