Sarah Palin’s Defamation Lawsuit Against The New York Times Revived: A New Trial Ordered
A federal appeals court has again overturned the dismissal of a defamation lawsuit filed by former Alaska Governor Sarah Palin against The New York Times, ordering a new trial in the case. The court found that the judge presiding over the original trial had improperly intruding on the jury’s role by dismissing the lawsuit before the jury had returned its verdict. This significant decision could have implications for future defamation cases, particularly those involving public figures.
Key Takeaways
- The 2nd Circuit U.S. Court of Appeals ruled that Judge Jed Rakoff’s dismissal of Palin’s lawsuit was incorrect.
- The appeals court stated that Rakoff "improperly intruded on the province of the jury by making credibility determinations" and by dismissing the lawsuit before the jury had returned its verdict.
- The new trial will be a significant opportunity for Palin to present her case again, potentially including evidence that was excluded during the original trial.
- This decision could have significant implications for the future of defamation lawsuits against media outlets.
Background on the Case
In 2017, The New York Times published an editorial that suggested a link between a 2011 shooting of then-Rep. Gabby Giffords of Arizona and a digital graphic published by Palin’s political action committee in 2010. Palin claimed the editorial defamed her by falsely implicating her in the shooting. In her complaint, she alleged that the Times acted with "actual malice," meaning they knew the editorial was false.
The lawsuit was initially dismissed by Judge Rakoff in 2019, ruling that Palin did not sufficiently plead a claim of "actual malice." However, the 2nd Circuit Court of Appeals reinstated the lawsuit. A jury trial began in February 2022, during which Rakoff, after hearing all the evidence, dismissed the lawsuit once again. In his decision, he found that no reasonable jury could find that the Times was motivated by actual malice against Palin.
The Appeals Court’s Reasoning
The court in its latest ruling asserted that Rakoff’s decision to dismiss the lawsuit before the jury returned its verdict was a mistake. The court cited “several major issues at trial," including "erroneous exclusion of evidence, and inaccurate jury instruction," a "legally erroneous response" by Rakoff to a question from jurors and "jurors learning during deliberations" of Rakoff’s dismissal of the complaint.
The court further emphasized that the jury plays a crucial role in our legal system. “The jury is sacrosanct in our legal system, and we have a duty to protect its constitutional role, both by ensuring that the jury’s role is not usurped by judges and by making certain that juries are provided with relevant proffered evidence and properly instructed on the law," the court stated.
Impact and Implications
The court’s decision is a major victory for Palin and could have far-reaching implications for other defamation cases. This case provides a clear reminder of the importance of the jury role in our legal system and the need to ensure that juries are entrusted with the responsibility of making decisions based on all the evidence and proper instructions.
For Palin, the new trial presents another chance to prove her case and potentially secure a significant settlement. For The New York Times, the decision means facing a new trial and facing the possibility of a costly outcome.
The decision could also change the dynamics of defamation lawsuits filed against media outlets. By emphasizing that judges should not interfere with the jury’s role, the court is signaling a potential shift towards a more robust defense of the First Amendment rights of individuals accused of defamation.
Furthermore, the court’s specific criticisms of how the trial was conducted could lead to greater scrutiny of the way defamation cases are tried. The court’s detailed analysis of the issues surrounding the exclusion of evidence and jury instructions raises concerns about the potential for bias or unfairness in these types of proceedings.
Looking Ahead
The new trial in the Palin case is likely to be closely watched by legal experts, journalists, and the public at large. Both sides will have the opportunity to present their arguments to a jury and hope for a favorable outcome. The trial could also serve as a precedent for future defamation cases, potentially influencing the way these cases are handled and the standards used to evaluate them.
The outcome of the new trial will have a lasting impact on the relationship between public figures, the media, and the law. It will be crucial to see how the jury weighs the evidence, interprets the law, and ultimately decides on the fate of Palin’s defamation lawsuit against The New York Times.
