Today, the 11th Circuit Court of Appeals upheld the lower court's decision and tossed a claim by the former offensive line coach of the Miami Dolphins (Turner) that the NFL's commissioned report on Bullygate (re: Jonathan Martin) was defamatory toward Turner. In tossing the case, the 11th Circuit determined that as an NFL coach, Turner was a public figure and thus needs to show actual malice to prevail on a defamation claim:
“We disagree with Coach Turner’s contention that he cannot be considered a limited public figure because he did not attempt to influence this public controversy,” Hull said. “When Turner took the job as the offensive line coach for the Dolphins NFL team, he thrust himself into the public limelight inherent in professional sports and well within the public controversy arising from Martin’s bullying. Even if Turner’s players were mainly responsible for the bullying, and therefore the scandal, this does not prevent Turner from becoming a public figure.”
Hull concluded that because Turner is a public figure, he must establish “actual malice” to maintain a defamation action, which he did not.
We have had prior threads related to this topic, so it may be of interest to some.
“We disagree with Coach Turner’s contention that he cannot be considered a limited public figure because he did not attempt to influence this public controversy,” Hull said. “When Turner took the job as the offensive line coach for the Dolphins NFL team, he thrust himself into the public limelight inherent in professional sports and well within the public controversy arising from Martin’s bullying. Even if Turner’s players were mainly responsible for the bullying, and therefore the scandal, this does not prevent Turner from becoming a public figure.”
Hull concluded that because Turner is a public figure, he must establish “actual malice” to maintain a defamation action, which he did not.
We have had prior threads related to this topic, so it may be of interest to some.
