Back in August 2022, golfer Patrick Reed filed a $750 million defamation lawsuit against Golf Channel commentator Brandel Chamblee and the overall channel. In the months after that, Chamblee added Fox Sports, the Associated Press, The New York Post, Gannett, Bloomberg, and several notable individual writers to that suit and a second one, targeting 18 total defendants and seeking a total $1 billion in combined damages. The initial suits were filed in Texas, then dismissed and refiled in Florida, then dismissed with permission to file amended complaints, and now, dismissed after those amended complaints:
Here's my @FOS story on the judge's decision to dismiss the cases, including a link to the order. https://t.co/9sNB6GYLXW
— A.J. Perez (@byajperez) September 27, 2023
Here’s more on what happened there from Perez’s story:
Timothy J. Corrigan, chief judge for the U.S. District Court for the Middle District of Florida, listed several reasons for dismissing the litigation against Golf Channel, analyst Brandel Chamblee, the Associated Press, Bloomberg, and others that sought at least $1 billion in damages combined.
“Because Reed is a public figure, he must sufficiently allege facts showing actual malice by the defendants to maintain his claims,” Corrigan wrote in his 78-page order. “To satisfy this standard, Reed must allege facts sufficient to give rise to a reasonable inference that the false statement was made ‘with knowledge that it was false or with reckless disregard of whether it was false or not.’
“Reed’s amended complaints in both lawsuits fall short of alleging sufficient facts showing that any Defendant had actual malice. This deficiency is fatal to each defamation claim.”
Corrigan dismissed the amended complaints with prejudice, meaning the claims can’t be refiled. He also set an October 20 deadline for the defendants to file motions ahead of a decision on whether the former Masters champ would have to pay attorney fees.
Indeed, the actual malice hurdle here (established in the 1964 Supreme Court case NYT v. Sullivan) means defamation cases in the U.S. have a very high bar to clear relative to other jurisdictions. And most of the successful court results against U.S. media organizations have not actually been on defamation actions, but rather on related causes of action. So, yes, this was always a possible outcome since the initial suit filing. But it’s still notable to see it go down this way.
