A review of Massachusetts cases shows consistent categorization of similar allusions to mental health as expressions of opinion or "rhetorical hyperbole." See Fleming v. Benzaquin, 390 Mass. 175, 181-84 (1983) (terms "absolute barbarian" and "nut" characterizing the plaintiff's conduct are not actionable for defamation): Mourad v. Boston Globe Newspaper Co., 60 Mass.App.Ct. 1106 at 2 (2003) (referring to an individual as "paranoid" is hyperbole because "no reasonable person could interpret the statement as a disclosure that the plaintiff suffers from clinical paranoia"): Tech Plus, Inc. v. Ansel, 59 Mass.App.Ct. 12, 16-17 (2003) (employee's statement that his supervisor was "sick" and "mentally ill" constitutes rhetorical hyperbole and not defamatory fact). Loughman's complaint is dismissed for failure to state a claim because "lunatic," as republished by Feeley, is a statement of opinion, and thus fails to satisfy the basic element of defamation which requires a statement of fact.