A brief barroom brawl has been the subject of a protracted legal battle, one that has outlived one of the brawlers. In 2006, Chris Kyle wrote an anecdote in his best-selling autobiography American Sniper in which he punched out a man called “Scruff Face” for speaking ill of Navy SEALs in Iraq. Scruff Face was later revealed to be Jesse Ventura — a former Navy SEAL himself and former Governor of Minnesota, who fought back legally.
Ventura sued Kyle for defamation in a case that lasted longer than the sniper himself. Kyle is now deceased and Ventura was awarded $ 500,000 in damages for the defamation, plus $ 1.35 million of the profits from Kyle’s book based on unjust enrichment. But today an appeals court overturned that award, according to The Hollywood Reporter.
Defamation Claim Remanded
The author of American Sniper, who was the most deadly sniper in US history, would no doubt be pleased with today’s legal results. Ventura’s claims were killed … almost.
Kyle’s wife appealed the damages award and in today’s opinion, the 8th Circuit Court of Appeals voted 2-1 to set aside the $ 500,000 defamation award because of improper and prejudicial testimony about Kyle’s insurance, remanding it for a new trial. Still, it is possible — and maybe even likely — that Ventura and Kyle’s widow will settle the claim rather than go through a trial again, particularly in light of what happened to the unjust enrichment argument and award.
Unjust Enrichment Reversed
The award for unjust enrichment was reversed altogether and will not be heard again. Media companies had opposed this particular claim and argued in briefs to the court that awarding profits from the book under an unjust enrichment theory would have a potentially crippling effect on free speech. The 8th Circuit agreed, noting that damages available under a defamation claim are an adequate legal remedy and that Ventura offered no precedent to support his claim.
“Neither the district court nor Ventura cited any case awarding profits in a defamation case under an unjust-enrichment theory, or even suggesting money damages are an inadequate remedy in a public-figure defamation case,” according to the opinion authored by 8th Circuit Judge William Jay Riley. “We find none … We cannot accept Ventura’s unjust-enrichment theory, because it enjoys no legal support under Minnesota law.”
Related Resources:
- For the latest legal entertainment news, subscribe to FindLaw Newsletters. (FindLaw Newsletters)
- Defamation Law: The Basics (FindLaw’s Learn About the Law)
- Defamation, Libel, and Slander: Background (FindLaw’s Learn About the Law)
- Defamation and Social Media: What You Need to Know (FindLaw’s Learn About the Law)
- Defamation vs. False Light: What Is the Difference? (FindLaw’s Learn About the Law)