Court of appeals dismissal of defamation lawsuit by former coach for Miami Dolphins

Turner v. Wells, 2018 WL 456955 (11th Cir. 2018)

In Turner, the United States Court of Appeals for the Eleventh Circuit, upheld the District Court’s decision to dismiss a defamation case, involving a former coach for the Miami Dolphins.

In 2013, Jon Martin, a player for the Miami Dolphins, left the team mid-season and checked himself into a hospital for psychological treatment. Martin later explained that he left the team due to persistent taunting. The National Football League (NFL) hired the New York law firm of Paul, Weiss and partner Theodore Wells, Esq., to investigate the taunting allegations. Mr. Wells’ investigation concluded that both the players and Coach Turner had been bullying Martin and the persistent harassment did cause him to leave the team. Furthermore, the report stated that the players and coaches enabled the bullying. Five days after the report was released the Dolphin’s fired Coach Turner. Mr. Turner filed a defamation case against the defendant. The defendant law firm, argued that the report consisted of opinions which are not actionable and the complaint misstated the report.

To prove defamation under Florida law, a party must establish that (a) defendant knowingly or recklessly made a false statement of fact, was defamatory and (b) the statement was published causing actual damages. If a statement is considered pure opinion, it is not actionable, whereas certain statements of fact are. A statement of fact is one that can be proven true or false. A true statement is one which can’t be proven false and is protected against defamation.

Furthermore, Coach Turner was a public figure who failed to plead actual malice. To prove actual malice, the plaintiff must prove that the defendant made the statement with knowledge that the statement was false, or with reckless disregard of whether it was false or not. The Eleventh Circuit agreed that the alleged defamatory statements in the report were not actionable. The Court also determined that Coach Turner failed to adequately plead actual malice.

Defamation cases adversely impact someone’s reputation. Having the right counsel to guide you through the legal process, while making sure your rights are protected is essential. If you or someone you know has a defamation claim or has been sued for defamation, please contact the lawyers at Kahn & Resnik, P.L. Our lawyers proudly serve all of Florida and will guide you through every step of the legal process. Call us now at 954-321-0176 to set up a consultation.