Facts

Sheriff Joseph Michael Arpaio filed suit against CNN President Jeff Zucker, CNN broadcaster Chris Cuomo, CNN, Kevin Robillard, Huffington Post, Tessa Stuart, and Rolling Stone in relation to defendants' publications concerning Arpaio.

PLAINTIFF'S CONTENTIONS: Arpaio alleged that he was the target of three defamatory publications produced by defendants that falsely referred to him as a convicted felon. Specifically, Arpaio alleged that a January 10, 2018 CNN broadcast featured Cuomo discussing Arpaio and falsely stating that Arpaio was a convicted felon. Arpaio contended that CNN took no action to correct the error. Arpaio alleged that a November 5, 2018 article published by Huffington Post and written by Robillard falsely stated that Arpaio had been sent to prison for contempt of court, and no actions were taken to correct the false statement. Arpaio also contended that a November 13, 2018 article pubished by Rolling Stone falsely referred to Arpaio as an ex-felon, and although a correction stated that Arpaio was convicted of a misdemeanor and pardoned, no correction of the ex-felon characterization was made. Arpaio contended that these false statements harmed his reputation and negatively impacted his chances of election to the U.S. Senate in 2020. In addition to his cause of action for defamation, Arpaio also asserted claims for tortious interference with prospective business relations and false light.

DEFENDANTS' CONTENTIONS: Defendants argued their statements were substantially true, and Arpaio could not prove that the statements were made with actual malice as required to sustain his claims. The Huffington Post defendants argued that Arpaio was libel-proof because their erroneous communication could not damage Arpaio's reputation any further.

Damages

Arpaio sought $300 million in damages.

Result

The court granted defendants' motion to dismiss. The court concluded that Arpaio's complaint did not adequately plead actual malice, and he merely pleaded that he believed the erroneous communications made by defendants were motivated by differences in political opinions. The court determined that the dismissal of Arpaio's defamation claim required dismissal of his tortious interference and false light claims as well.

Other Information

JUDGE: Hon. Royce C. Lamberth.