A Project Manager Applied for a Job, and Listed His

A project manager applied for a job, and listed his previous employer as a reference. When the prospective employer called, the man who gave a reference for the project manager falsely implied that the project manager was incompetent, even though he had never worked with or supervised the employee, nor checked any employment records.  The project manager did not get the new job. If the project manager sues his former employer for defamation, the court will likely rule that:  ​

A) the employer did not defame the former employee because its statements were merely opinions and did not purport to be factual ​
B) the employer did not defame the former employee because the statements, although harsh, were truthful
C) the employer defamed the former employee because statements made in references are not subject to qualified privilege
D) the employer defamed the former employee because the employer was recklessly indifferent to the truthfulness of the statements made