1-14 Oprah Winfrey was sued for, in pertinent part, intentional infliction of emotional distress after making statements about Lerato Nomvuyo Mzamane's performance as headmistress of the Oprah Winfrey Leadership Academy for Girls (OWLAG). OWLAG is a private academy in South Africa that provides education for children from impoverished families. After learning that one of the individuals working at the school had been abusive toward the students, Winfrey made statements to the effect that she had "lost confidence in [Mzamane's] ability to run the school," that Mzamane had failed to take student complaints "seriously," that the abusers thought they were "protected by [Mzamane]," and other similar statements. Winfrey moved for summary judgment. How do you think the court ruled? Does it matter whether this is a jurisdiction that requires a physical injury to succeed on a claim for intentional infliction of emotional distress? Are there any other claims that the plaintiff could or may have pursued in this case? Mzamane v. Winfrey, 2010 U.S. Dist. LEXIS 23491 (2010)