United States District Court for the District of Minnesota
8 F.Supp.3d 1115 (2014)
Chris Kyle (defendant) was a Navy SEAL and the author of American Sniper, the Autobiography of the Most Lethal Sniper in the U.S. Military History. A subchapter of this book described an interaction with Jessie Ventura (plaintiff), a former wrestler, actor, and governor of Minnesota. This subchapter detailed a heated argument about the Navy SEALs between Kyle and an individual referred to as Scruff Face. Kyle later admitted that Scruff Face was Ventura. In the book, Ventura is quoted as saying that the SEALs deserved to lose a few soldiers in the Iraq war. Kyle wrote that he punched Ventura and knocked him out. Kyle also wrote that it was rumored that Ventura had a black eye afterward. Ventura sued Kyle for defamation. Kyle presented two witnesses who corroborated Ventura’s comments and Kyle’s punch. Ventura presented several witnesses that refuted Kyle’s description of the interaction. Ventura also presented photographs from the following day that showed Ventura did not have any injuries. While the litigation was pending, Kyle was killed. Kyle’s wife became the executrix of his estate and filed a motion for summary judgment, asserting that: (1) the statements in the book were not false and (2) Kyle did not act with actual malice.
Rule of Law
Holding and Reasoning (Kyle, J.)
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