Jessica Was a Former Employee of Mark

Jessica was a former employee of Mark.When potential employers called Mark for a reference about Jessica,he stated she was not a very good worker and had been fired for excessive absences.He said he believed Jessica was on drugs,but he did not know for sure.Jessica learned what Mark was saying and sued him.In most states:

A) it was legal for Mark to say what he said if it was true and Mark was not motivated by ill will.
B) it was legal for Mark to say what he said, since courts have consistently ruled that former employers are immune from lawsuits for giving references.
C) it was not proper for Mark to say what he said, since courts have consistently ruled that former employers should not give references over the telephone or in writing without the former employee's written authorization.
D) though it was proper for Mark to talk about Jessica's work-related history, he acted improperly when he said he thought she was on drugs.