Brooks v. American Broadcasting Companies, Inc.
United States Court of Appeals for the Sixth Circuit
932 F.2d 495 (1991)
- Written by Sharon Feldman, JD
Facts
A judge in Akron, Ohio, was rumored to have persuaded women to have sex with him in exchange for favorable rulings in cases. Television personality Geraldo Rivera traveled to Akron to investigate whether William Brooks (plaintiff) was trying to frighten women out of testifying against the judge. Brooks had a substantial criminal history, including convictions for breaking and entering, grand larceny, first-degree manslaughter, and carrying a concealed weapon under disability. The local paper had published four articles about Brooks’s convictions and noted that Brooks had been involved in a murder. On the television program 20/20, American Broadcasting Companies, Inc. (ABC) (defendant) broadcast comments by Rivera and others that the judge employed Brooks as a “hitman” and Brooks was a “pimp,” a “muscleman,” and a “street knowledgeable jive turkey.” Before the segment aired, Brooks was indicted on obstruction-of-justice charges, and the local newspaper reported that Brooks had been indicted for intimidating witnesses and obstructing justice to assist the judge and was suspected of being the “hitman” in the case. Brooks sued ABC for libel based on Rivera’s remarks. The trial court granted summary judgment to ABC, finding as a matter of law that Brooks was libel-proof. Brooks appealed.
Rule of Law
Issue
Holding and Reasoning (Ryan, J.)
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