Eugene Volokh: Delaware S. Ct. Rejects Defamation Claim Brought by Repair Shop Owner Who Provided Hunter Biden Laptop to Media
The Delaware Supreme Court has rejected a defamation claim brought by a repair shop owner, Mac Isaac, who provided the laptop of Joe Biden's son, Hunter Biden, to the media. The court ruled that the allegedly defamatory statements did not concern the plaintiff shop owner and thus were not actionable.
In October 2020, Politico published an article with a headline that stated, "Hunter Biden story IS Russian disinformation." Mac Isaac, who owned a computer repair shop in Delaware, had provided the laptop to the media. He conceded that the article was "substantially true," but argued that the headline was false and defamatory.
Mac Isaac's argument centered on the idea that the headline implied he was part of a Russian disinformation campaign, which he claimed would damage his reputation and subject him to distrust, scorn, ridicule, hatred, and contempt in his community, as well as the loss of his business.
The court rejected this argument, stating that the headline did not mention Mac Isaac or provide any information from which a reader might think that he was a participant in a "Russian information operation." The only statement below the headline mentioned him, but it was true and accurately reported the facts.
Key Points of the Court's Ruling
- The court held that the allegedly defamatory statements did not concern the plaintiff shop owner and thus were not actionable.
- The headline did not imply Mac Isaac was part of a Russian disinformation campaign, but rather stated that the "Hunter Biden story" was in fact Russian disinformation, which had not been concluded by former intelligence officials.
- A false statement is not defamatory when it does not concern the plaintiff.
- Mac Isaac's argument relied on a narrow reading of the headline, ignoring its accurate and non-defamatory content in the article below.
- The court rejected Mac Isaac's claim against the Biden For President Campaign Committee on procedural grounds, as well as Biden's cross-appeal against Mac Isaac for allegedly invading Biden's privacy.
Implications of the Ruling
The Delaware Supreme Court's decision has significant implications for defamation claims involving public figures and third-party publications. It highlights the importance of understanding the context and content of alleged defamatory statements, as well as the limitations of relying on a single headline to imply a connection between a plaintiff and a defamatory statement.
The ruling also underscores the need for plaintiffs to carefully consider their claims and provide sufficient evidence to support their allegations. In this case, Mac Isaac's argument relied too heavily on a narrow reading of the headline, ignoring its accurate and non-defamatory content in the article below.