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Agnant v. Shakur
United States District Court for the Southern District of New York
30 F. Supp. 2d 420 (1998)
In 1993, Jacques Agnant (plaintiff) and Tupac Shakur (defendant) were arrested for sexually assaulting a woman. The charges against the two were severed. Shakur was convicted in 1994. Months later, Agnant pleaded guilty to lesser charges and received a lighter sentence. After Shakur’s death in 1996, a song titled “Against All Odds” was posthumously released by Shakur’s estate. The song contained lines referring to “Haitian Jack” and alleged that he was “working for the fed.” Agnant worked in an executive capacity at the record company Undeas Entertainment. Despite this, Agnant filed suit against Shakur’s estate and his record company (defendant) for libel, claiming that the lyrics contained in the song caused him to be unable to find employment commensurate with his training and experience and destroyed his reputation in the community. Shakur’s estate moved for summary judgment, arguing that the statements did not have defamatory meaning, that Agnant failed to plead special damages, that the statements were protected opinions, and that Shakur’s celebrity status made the case a matter of public concern requiring actual malice.
Rule of Law
Holding and Reasoning (Mukasey, J.)
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