Pippen v. NBC Universal Media, LLC

Dist. Ct. did not err in granting defendants-news organizations’ motion to dismiss plaintiff’s defamation action, even though plaintiff-ex-Chicago Bull basketball player alleged that defendants published false reports that plaintiff had filed for bankruptcy, and that said false reports impaired plaintiff’s ability to earn living through product endorsements and personal appearances. Said reports did not qualify as defamation per se since false report of bankruptcy did not imply that plaintiff lacked competency or integrity to perform current occupations of being goodwill ambassador to Bulls, as well as basketball analyst and celebrity product endorser. Moreover, plaintiff could not establish defamation per quod claim since: (1) any failure of defendants to clarify plaintiff’s bankruptcy status is insufficient to establish reckless disregard for truth element of plaintiff’s claim; and (2) proof of defendants’ actual malice required for instant lawsuit cannot be inferred from defendants’ failure to retract statement once it learned that they were false. Ct. also rejected plaintiff’s contention that Uniform Single Publication Act, which provides that claim for defamation is complete upon original publication, did not apply to instant false statements made on Internet.