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Disinformation and propaganda – impact on the functioning of the rule of  law in the EU and its Member States

We have been following a slew of defamation lawsuits by political figures over the last few years. (See, e.g., here and here and here and here and here and here and here and here). For torts scholars, it has been a bonanza of interesting issues touching on every element of defamation law. There is now an important ruling out of the United States Court of Appeals for the Eighth Circuit that could have enormous implications not just for the media but anyone who retweets stories or claims. The appellate panel ruled unanimously for Rep. Devin Nunes against journalist Ryan Lizza who now writes for Politico. Nunes will be allowed to litigate his claim that Lizza defamed him by claiming that he secretly moved his farm from California to Iowa and linked the move to the alleged use of undocumented labor. Not only does Nunes have no reported stake or operational involvement with the farm, there is no evidence of his effort to hide the move or conceal any use of undocumented laborers. However, the interesting aspect of the ruling is how a retweet by Lizza resuscitated the case for Nunes.

In 2019, Nunes sued Lizza and Hearst Magazines after Lizza wrote a feature article entitled “Devin Nunes’s Family Farm Is Hiding a Politically Explosive Secret,” in Esquire. Lizza asked in the article “Why would the Nuneses, Steve King, and an obscure dairy publication all conspire to hide the fact that the congressman’s family sold its farm and moved to Iowa?” The “explosive secret” appeared to be his moving the family dairy farm to Iowa from his district and the suggestion that the farm was using undocumented labor.

The claims, if false, could be the basis for defamation and a separate lawsuit against Lizza and Hearst by the family farm, NuStar, was previously found valid for the purposes of a trial. The issue was the separate Nunes complaint and federal judge C.J. Williams rejected his claims because “[m]oving or concealing a move is not a crime. Because the object of the ‘conspiracy’ is harmless, no reasonable reader could interpret the term ‘conspiracy’ to imply criminal conduct in this context.”

The appellate panel agreed that there was no express defamatory statement in the article. However, it found that a reasonable jury could find it defamatory by implication. As such, the statements do no need to be individually defamatory by creates defamatory meaning in the juxtaposing of fact or omitting facts. The court ruled that “[b]ased on the article’s presentation of facts, we think the complaint plausibly alleges that a reasonable reader could draw the implication that Representative Nunes conspired to hide the farm’s use of undocumented labor.”

The problem for Nunes is that he is a public official. The standard for defamation for public figures and officials in the United States is the product of a decision decades ago in New York Times v. Sullivan. This is precisely the environment in which the opinion was written. The Supreme Court ruled that tort law could not be used to overcome First Amendment protections for free speech or the free press. The Court sought to create “breathing space” for the media by articulating that standard that now applies to both public officials and public figures. As such, public officials and public figures must show either actual knowledge of its falsity or a reckless disregard of the truth.

read more:

https://jonathanturley.org/2021/09/21/rep-nunes-wins-major-victory-in-defamation-case-against-ryan-lizza-and-hearst/

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