How have courts dealt with defamation claims against a former employee who defamed a plaintiff?

Balasubramanian's reliance on Agarwal v. Johnson, supra, 25 Cal.3d 932, is misplaced. In that case, the plaintiff was terminated from employment and remained unemployed for 13 months. His former employee made unfavorable statements about him to prospective employers. (Id. at p. 943.) The plaintiff sued in state court, alleging defamation, infliction of emotional distress and interference with business relationships. (Id. at p. 944.) He also filed a discrimination claim under title VII of the Civil Rights Act of 1964 (42 U.S.C. 2000e et seq.) (title VII) in federal court. Before final judgment in the state action, the federal court found plaintiff had not met his burden of proving discrimination. Defendants then argued the federal judgment was a bar to the state action under principles of res judicata. (Id. at p. 954.)