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Mzamane v. Winfrey
United States District Court for the Eastern District of Pennsylvania
693 F. Supp. 2d 442 (2010)
At all relevant times, Lerato Mzamane (plaintiff) was domiciled in Pennsylvania. Around 2007, Mzamane accepted a position as headmistress at a South African school opened by Oprah Winfrey (defendant). Mzamane traveled to and from South Africa for her job. During Mzamane’s tenure as headmistress, some students at the school complained about their experiences, and these complaints were reported by the media. In October 2007, Winfrey made some allegedly defamatory statements about Mzamane at an Illinois meeting with the students’ parents. In November 2007, Winfrey held a press conference during which she allegedly made further defamatory statements. A recording of the press conference was publicly available on a website, including in Pennsylvania, until May 2009. Mzamane had a difficult time finding a new job after Winfrey’s statements were publicized. Mzamane sued Winfrey in state court for defamation, and the action was removed to federal district court in Pennsylvania based on diversity jurisdiction. Winfrey filed a motion for summary judgment, requiring the court to decide which state’s law would apply.
Rule of Law
Holding and Reasoning (Robreno, J.)
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