On September 29, 2025, the U.S. District Court for the Northern District of Illinois (Judge Jeffrey I. Cummings) largely denied a Rule 12(b)(6) motion to dismiss in Kuo v. Resilience Health Care—West Suburban Medical Center, LLC and Dr. Manoj Prasad (No. 25‑cv‑1846), allowing Dr. Kira Kuo’s defamation per se that allegedly accused her of misconduct. The Court held that defendants’ “opinion,” “truth,” and qualified‑privilege defenses could not be resolved at the pleading stage. Kuo’s separate claims for retaliatory discharge and ERISA violations were not at issue in this motion and remain pending.
