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Pippen v. NBCUniversal Media, LLC

United States Court of Appeals for the Seventh Circuit

734 F.3d 610 (2013)

Facts

Scottie Pippen (plaintiff) encountered financial setbacks after retiring from professional basketball, and he sued several former advisors whom he considered responsible. Various media outlets falsely reported that Pippen had filed for bankruptcy. Pippen then brought suit against NBCUniversal Media, LLC (NBC) (defendant) and other media companies for defamation and false light. Pippen argued that the false reports had damaged his ability to derive income from personal appearances, product endorsements, and basketball analysis. Pippen also asserted that the Single Publication Act, which makes a defamation claim complete at the time of first publication, did not apply to online publications, in which many of the false reports appeared. The district court dismissed Pippen’s complaint, ruling that Pippen failed to establish evidence of both financial injury and actual malice by the media companies. Pippen appealed. The United States Court of Appeals for the Seventh Circuit granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Easterbrook, C.J.)

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