Herring Networks, Inc. v. Maddow

8 F.4th 1148 (2021)

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Herring Networks, Inc. v. Maddow

United States Court of Appeals for the Ninth Circuit
8 F.4th 1148 (2021)

SC

Facts

Kristian Rouz was a reporter for One American News Network (OAN), which was owned by Herring Networks, Inc. (Herring) (plaintiff). Simultaneously, Rouz freelanced for Russian-financed Sputnik News. After an article was published in The Daily Beast noting Rouz’s two jobs, Rachel Maddow (defendant) ran a segment on Rouz on The Rachel Maddow Show on MSNBC. During the segment, Maddow expressed gleeful shock at the story of Rouz’s dual employment and said that OAN “really literally is paid Russian propaganda.” Herring sued Maddow for defamation. Herring stated that OAN was never paid by Russia or the Russian government. The district court held that Maddow’s statement was not defamatory. Herring appealed.

Rule of Law

Issue

Holding and Reasoning (Smith, J.)

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