Clary v. Pennsylvania State Univ., decided Dec. 2 by Chief Judge Matthew Brann (M.D. Pa.), involves a claim that the Penn State basketball head coach Michael Rhoades defamed Kanye Clary, the team's student captain. The court concluded that two statements were sufficiently alleged to be actionable:
Paragraph 41 alleges that Rhoades, in January and February 2024, "spread rumors to staff, media and surrounding people that [Clary's] father, Anthony Clary, was after more money which is the reason why [Clary] did not return." … [A]lthough the statement only references Clary's father, it also states that Clary refused to return to Penn State due to the desire—whether his or his father's—for more money. This can reasonably be inferred as a defamatory statement about Clary—that Clary himself was greedy and only interested in money and, as a result, abandoned [his] team and refused to play for Penn State…. [And] it may be reasonably inferred that this statement damaged Clary; the statement created a stigma related to Clary that forced him to play at a less prestigious university and directly led to financial losses and the "derailment" of his basketball career….
