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Farah v. Esquire Magazine, Inc.
United States Court of Appeals for the District of Columbia Circuit
736 F.3d 528 (2013)
Facts
Jerome Corsi (plaintiff) wrote a book whose main title was Where’s the Birth Certificate? The book purported to explain that President Obama was not a citizen of the United States. It was published by WND Books, which was owned by Joseph Farah (plaintiff). Although Obama released his Hawaii birth certificate three weeks before publication of the book, Corsi and Farah remained undeterred, arguing that the birth certificate was a forgery. Journalist Mark Warren (defendant) then wrote a satirical article for the Esquire Magazine, Inc. (Esquire) (defendant) politics blog, which frequently published satire in addition to straight news. The article stated that Corsi’s book had been pulled from the shelves and that WND was offering refunds to those who had purchased it. This allegedly led to media outlets contacting Corsi and Farah for comment, requests for refunds, and stores pulling the book from shelves in actuality. Approximately 90 minutes after publication of Warren’s article, the Esquire blog posted an update explaining that the article was satire. Corsi and Farah brought suit for defamation, seeking compensatory and punitive damages. The district court dismissed the complaint. Corsi and Farah appealed. The United States Court of Appeals for the District of Columbia Circuit granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Rogers, J.)
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