A listing in a directory of lawyers that described an attorney as an “ambulance chaser” interested only in “slam dunk cases” provides the basis for a claim of defamation, the U.S. Court of Appeals for the Second Circuit has ruled.

Finding that the description of attorney Leonard Flamm stood alone in “an otherwise fact-laden” directory, a unanimous court found that the statements were not protected by the First Amendment or the New York Constitution in Flamm v. American Association of University Women, 99-7085.

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