A federal judge dismissed both of Patrick Reed’s defamation cases against 18 total defendants on Wednesday.
Timothy J. Corrigan, chief judge for the U.S. District Court for the Middle District of Florida, listed several reasons for dismissing the litigation against Golf Channel, analyst Brandel Chamblee, the Associated Press, Bloomberg, and others that sought at least $1 billion in damages combined.
“Because Reed is a public figure, he must sufficiently allege facts showing actual malice by the defendants to maintain his claims,” Corrigan wrote in his 78-page order. “To satisfy this standard, Reed must allege facts sufficient to give rise to a reasonable inference that the false statement was made ‘with knowledge that it was false or with reckless disregard of whether it was false or not.’
“Reed’s amended complaints in both lawsuits fall short of alleging sufficient facts showing that any Defendant had actual malice. This deficiency is fatal to each defamation claim.”
Corrigan dismissed the amended complaints with prejudice, meaning the claims can’t be refiled.
“The decision was seriously flawed — factually and legally — and showed [Corrigan had] a mindset against Patrick,” Larry Klayman, Reed’s attorney, told Front Office Sports. “
Klayman, who made a name for himself in the legal and political community as the founder of right-wing activist group Judicial Watch, said he will seek to get Corrigan’s judgment set aside. If Corrigan denies that motion, Klayman said he’d file an appeal on Reed’s behalf.
Corrigan set an Oct. 20 deadline for the defendants to file motions ahead of a decision on whether the former Masters champ would have to pay attorney fees. Klayman said that since the venue for the cases was in a federal courtroom, Florida’s anti-SLAPP law — which makes it easier for defendants to recover attorney fees for frivolous lawsuits — can’t be relied upon.
“Numerous federal courts have held that [a state) anti-SLAPP law does not apply in cases [like] this,” said Klayman
Corrigan initially dismissed both cases, although he allowed Reed to file amended complaints.
“There is no reason to think that a third amended complaint would be different,” Corrigan wrote in Wednesday’s decision. “These overwhelming deficiencies, coupled with his previous failed attempt at pleading both complaints, demonstrates that further amendment would be futile.”
A message left with Klayman was not immediately returned.
Corrigan reasoned that only one of the many claims “may be defamatory, but none of the other alleged statements survive the motions to dismiss.” The claim was related to a New York Post story published last September that republished part of “The Cup They Couldn’t Lose,” a book written by Shane Ryan.
“In 2008, Reed enrolled at the University of Georgia in Athens, but was kicked off the golf team for two alcohol violations,” the story stated. “He was also arrested for underage drinking and possessing a fake ID, given community service and put on probation.”
The New York Post story also mentioned “items including a watch, a putter and $400 went missing from the locker room,” and Reed’s college teammates “suspected it was Reed who had taken them.”
But Corrigan wrote the New York Post story “does not qualify as actual malice.”
Ryan, Hachette Book Group (the publisher of Ryan’s book), and the New York Post were among the defendants in one of the now-dismissed lawsuits.
Corrigan did grant a motion for a default judgment against Fox Sports, but that wasn’t much of a win for Reed since Corrigan dismissed the case against the network anyway.