21

See, e.g., Brewer v. Second Baptist Church, 197 P.2d 713 (Cal. 1948) (charges brought by church committee without malice and with reasonable belief in their truth); Crosby v. Lee, 76 S.E.2d 856 (Ga. 1957) (announcement of disciplinary results deemed privileged); Swafford v. Keaton, 93 S.E. 122 (Ga. 1919) (charges brought in good faith and in bona fide discharge of duty); Anderson v. Malm, 198 Ill. App. 58 (Ill. 1916) (words of presiding officer at expulsion meeting privileged as being in line of duty in relation to church discipline); Redgate v. Roush, 59 P. 1050 (Kan. 1900) (publication by church officers of expulsion of minister deemed privileged because standing in denomination of every minister is of “common interest” to every other minister); Butterworth v. Todd, 70 A. 139 (N.J. 1908) (announcing result of expulsion proceeding in good faith and within authority of church deemed privileged).