In what circumstances will a court strike down a defamation claim against a government official for defaming a third party?

In Sullivan v. State of New Jersey, 602 F.Supp. 1216, 1222 (D.N.J.1985), aff'd 853 F.2d 921 (3d Cir.1988) the district court quoted note 23 in Marrero (cited above) and stated its disagreement "that the logic of Paul leads to such a conclusion." In Sullivan, the plaintiff argued that the defamation by the government officials caused them to lose protected rights in contractual relations with third persons. The court found that this did not satisfy the stigma-plus test, because the state action did not directly affect the plaintiff's rights or status under the law.