Today's decision by Magistrate Judge Jill Morris in McClanahan v. Anti-Defamation League (W.D. Mo.), rejects plaintiff's libel claim; here's an excerpt:
Plaintiff, a recent political candidate in Missouri, initiated this lawsuit contesting an article entitled "ADL Researchers Identify Failed Extremist Candidates in Missouri and North Carolina," that was published on ADL's website on August 16, 2022…. Plaintiff alleges that the article falsely identified him as a "member of the Knight's party, Ku Klux Klan," falsely labeled him as a "White Supremacist, Sore Loser, Angry American", and falsely stated that his social media posts contain "anti-Semitic, anti-government, white supremacist, and bigoted content"). The Complaint further asserts other statements in the article are false and defamatory, including:
- The assertion that Plaintiff "did not openly express or share [his] extreme views during the primaries or in candidate forums."
- The statement that Plaintiff's candidacy serves as a "stark reminder that extremists, some of whom may purposefully hide their extremist beliefs, continue to seek public office with the hope of influencing mainstream society."
- That the article "attacks McClanahan's Honorary membership to the League of the South without investigating if McClanahan believed in Southern secession or a White dominated South." …
Each of the statements alleged to be defamatory by Plaintiff are nonactionable for various reasons. These reasons include being expressions of opinion, being substantially true according to Plaintiff's own assertions in the Complaint, failing to correspond accurately with the content of the article, and reflecting Plaintiff's own words….
