Media Law Prof Blog

Editor: Christine A. Corcos
Louisiana State Univ.

Wednesday, August 14, 2019

District Court Dismisses Arpaio Defamation Suit Against New York Times

The U.S. District Court for the District of Columbia has dismissed Joe Arpaio's defamation suit against the New York Times. In a short ruling, Judge Amit P. Mehta held that the plaintiff failed to allege sufficient facts "that plausbily establish 'actual malice.' Indeed, Plaintiff pleads no facts at all. Instead, throughout his Complaint, he does no more than recite the applicable legal standard." The court also wrote that the Plaintiff offered no facts to support his contention that the actual malice could be inferred because the defendant's "political partisanship and liberal bias know no reasonable bounds..." Plaintiff also asserted that "the very nature of Defendants' statements reveals that they must have known the statements were false when they published them." But, wrote Judge Mehta, "there is nothing about the Article's assertions of fact that makes them self-evidently false."

Mr. Arpaio also claimed that the New York interfered with his prospective business relations but that claim is based on the same facts as the defamation claim, and because he offered no facts to support the defamation claim, the tortious interference claim must fail as well. Plaintiff also advanced a false light claim, which, because Plaintiff is a public figure, requires a showing of actual malice. The Plaintiff failed to plead actual malice.

The judge dismissed the plaintiff's complaint with prejudice absent a motion to amend within 14 days and including a proposed amended complaint.


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