Ventura v. Kyle

Jesse Ventura (plaintiff) was a former governor of Minnesota. Chris Kyle was a former Navy Sea, Air and Land (SEAL) sniper who wrote a best-selling autobiography published by HarperCollins. In his book, Kyle claimed that he punched a celebrity he called Scruff Face after the celebrity made disparaging comments about the SEALs. In subsequent interviews, Kyle admitted that Ventura was Scruff Face. Ventura, who denied Kyle’s story, sued Kyle for defamation, misappropriation, and unjust enrichment. Taya Kyle (defendant), Kyle’s wife and the executrix of his estate, was substituted as the defendant following Kyle’s death. At trial, Taya testified that she had incurred legal expenses as a result of Ventura’s lawsuit and that she would have to pay a judgment if Ventura won. Ventura then sought to introduce evidence that Kyle was covered under a HarperCollins insurance policy, claiming that Taya’s testimony had opened the door to insurance evidence. Because Ventura conceded that the policy covered, at most, the defamation claim, the district court found that Taya’s testimony was accurate and that Ventura could thus not ask Taya about insurance. Ventura later asked two HarperCollins employees about Kyle’s and HarperCollins’s alleged insurance coverage during cross-examination. Ventura claimed that the insurance evidence was relevant to impeach the witnesses by showing that HarperCollins had a direct stake in the litigation and that the witnesses were biased toward Kyle. The district court permitted that questioning over Kyle’s objection. Both witnesses denied knowing anything about insurance. During closing argument, Ventura told the jury that HarperCollins’s insurer would be on the hook if the jury found in Ventura’s favor on his defamation claim. The district court denied Kyle’s subsequent motion for a mistrial. The jury struggled to reach a verdict. Ultimately, the jury rendered an eight-to-two verdict in Ventura’s favor on his defamation claim and awarded $500,000 in damages. Kyle appealed, arguing that the district court erroneously allowed Ventura to question the HarperCollins witnesses about insurance and to reference insurance during closing.