Law School Case Brief
Palin v. N.Y. Times Co. - 933 F.3d 160 (2d Cir. 2019)
In order to satisfy Fed. R. Civ. P. 8, a complaint must contain enough facts to state a claim to relief that is plausible on its face. A claim is plausible when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. A well-pleaded complaint will include facts that raise a right to relief above the speculative level. The plausibility standard is not akin to a probability requirement, but it asks for more than a sheer possibility that a defendant has acted unlawfully.
On June 14, 2017, a political shooting occurred when a gunman opened fire in Alexandria, Virginia at a practice for a congressional baseball game. Four people were seriously injured, including a Republican congressman. That same evening, The New York Times, which was operated by defendant The New York Time Company (collective, "Times"), published an editorial. The editorial argued that the recent shooting and a similar shooting in 2011, in which a Democratic Congresswoman was shot and injured, evidenced the "vicious" nature of American politics. In reference to the 2011 shooting, the editorial mentioned a map circulated by plaintiff Sarah Palin's political action committee that superimposed the image of a crosshairs target over certain Democratic congressional districts, suggesting a link between the map and the 2011 shooting. Palin thereafter filed a defamation action in federal district court against the Times. The Times filed a motion to dismiss. The district court held a hearing during which the editorial's author answered questions posed by both sides and the judge. The district court granted the motion. The district court determined that any amendment would be futile and dismissed Palin's complaint with prejudice. Palin's motion for reconsideration was denied, and she appealed.
Did the district court err in dismissing Palin's complaint?
The appellate court vacated the district court's judgment and remanded the case for further proceedings. The court held that the district court erred in relying on facts outside the pleadings to dismiss the complaint. The court noted that, on the Times' Fed. R. Civ. P. 12(b)(6) motion, when matters outside the pleadings—i.e., the author's testimony—were presented to and not excluded by the district court, the district court had only two options: (1) exclude the additional material and decide the motion on the complaint alone, or; (2) convert the motion to one for summary judgment under Fed. R. Civ. P. 56 and afford all parties the opportunity to present supporting material. The court ruled that district court took neither permissible route under Rule 12(d). The district judge both relied on matters outside the pleadings to decide the motion to dismiss and did not convert the motion into one for summary judgment. The court went on to hold that full discovery on the complaint was warranted because Palin's proposed amended complaint plausibly stated a claim for defamation by a public figure, particularly since the complaint alleged that she was a public figure, the disputed statement concerned her, and the statement was made with actual malice.
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