shelter it provides. “A vast majority of state rules regarding qualified privilege include a requirement of ‘good faith.’ ” A.G. Harmon, Defamation in Good Faith: An Argument for Restating the Defense of Qualified Privilege, 16 Barry L.Rev. 27, 30 n. 16 (2011). Modern iterations of the privilege by Michigan appellate courts make clear that a showing of “good faith” is essential to a defendant’s ability to invoke the privilege: “The elements of a qualified privilege are (1) good faith, (2) an interest to be upheld, (3) a statement limited in its scope to this purpose, (4) a proper occasion, and (5) publication in a proper manner and to proper parties only.” Prysak, 193 Mich.App. at 14-15, 483 N.W.2d at 636 (emphasis added) (citing Bufalino v. Maxon B . App. 590, 174 N.W.2d 875 (1970) (<HOLDING>); see also Haddad v. Sears Roebuck & Co., 526
holding that the defendant was not entitled to any qualified privilege for false accusations of theft given under the guise of employment references despite earlier holdings by michigan courts that had extended the privilege to statements of reference from a prior to a prospective employer holding that defendant could be charged for making false statements to treasury officials under the tax evasion statute or the statute prohibiting false statements to government officials holding that the doctrine of commonlaw privilege that grants immunity to witnesses in quasijudicial proceedings does not extend to disciplinary proceedings against a state employee who makes false statements in the course of an official investigation holding that defendants are not entitled to qualified immunity holding both that a defendants prior disciplinary history was properly precluded because it did not involve an element of deceit or falsification and that defendants earlier allegedly false statements could not be admitted because proving their falsehood would have required the introduction of extrinsic evidence showing the statements made to be false