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Haynes v. Alfred A. Knopf, Inc.
United States Court of Appeals for the Seventh Circuit
8 F.3d 1222 (7th Cir. 1993)
Alfred A. Knopf, Inc. (Knopf) (defendant) published a book titled “The Promised Land: The Great Black Migration and How It Changed America.” The book chronicles the move of five million African Americans between 1940 and 1970 from impoverished rural areas to what have been called “urban ghettos.” The author writes from a journalistic perspective and focuses primarily on the journey of one particular African American woman named Ruby Lee Daniels. In the book, Daniels is mentioned as marrying Luther Haynes (plaintiff). Haynes is described in an unflattering light as an alcoholic, an adulterer, and a poor worker and husband. Haynes ultimately divorced Daniels and married his current wife, Dorothy Haynes (plaintiff). Luther and Dorothy Haynes brought suit against Knopf and the book’s author, Lemann, for libel and invasion of privacy based on the characterization of Haynes in the book. The trial court granted summary judgment for Knopf, and Haynes appealed.
Rule of Law
Holding and Reasoning (Posner, C.J.)
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