First, an officer must show that the complaint is actionable under Arizona libel law. The State has perpetuated a distinction between libel per se, words which have a defamatory meaning apparent on their face, and libel per quod, where the meaning is innocent on the face and extrinsic facts are necessary to establish the defamatory meaning. In libel per quod, defendants must prove specific injury to reputation and pecuniary loss to recover. Recovery in defamation by police officers has been made more difficult because some courts require a greater showing of injury by an officer than is required of a nonofficer plaintiff. Second, the officer must establish that a citizen complaint to a police department is not absolutely privileged. Arizona courts have yet to decide whether a citizen complaint alleging police misconduct is absolutely privileged. Prior Arizona precedent announces that statements to an administrative body, which should include a complaint to the police, will not be absolutely privileged. Even if it is held that the police department does not qualify as an administrative body, a police investigation of a citizen complaint does not possess the traditional judicial safeguards necessary to permit the application of the absolute privilege. Third, the officer must meet the stringent New York Times actual malice standard, proving that the citizen complaint is made with requisite degree of constitutional fault, that is with reckless disregard of truth or falsity. Proof of all three elements of this test by a police officer plaintiff will be difficult. The paper includes 241 footnotes.