Steam Press Holdings, Inc. v. Hawaii Teamsters & Allied Workers Union, 302 F.3d 998 (9th Cir. 2002)

During the course of a labor dispute, union president Mel Kahele told a number of employees of the company (Steam Press Holdings, Inc.) that the owner of the company, Michael Drace, was “making money” and “hiding it in Steam Press.” Drace sued Kahele for defamation, among other