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Moldea v. New York Times Co.
United States Court of Appeals for the District of Columbia Circuit
22 F.3d 310 (1994)
Investigative journalist and author Dan Moldea (plaintiff) wrote a book called Interference. The New York Times Company (Times) (defendant) published a book review that criticized Interference for containing “too much sloppy journalism.” The review cited several examples of the book’s journalistic shortcomings. Moldea sued the Times for defamation. The district court granted summary judgment to the Times, and Moldea appealed. The court of appeals reversed the district court, finding that some of the characterizations in the Times review were potentially actionable because those characterizations could be factually verified for truth or falsity. The court of appeals therefore concluded that the district court could not properly rule that the characterizations were true as a matter of law. The Times filed a petition for rehearing, and the court of appeals reconsidered its decision.
Rule of Law
Holding and Reasoning (Edwards, J.)
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