I believe that they could.
Seeing as how the Watchtower 11/15/2006 p26-30 stated "Disfellowshipping takes place only if a member
of the congregation unrepentantly engages in gross sin.” If one is disfellowshipped, then the congregation would assume that the person unrepentantly engaged in gross sin. If there was no gross sin or no sin at all, then that is slander to DF someone.