The Daily Mail published an article that Michael Lindell, the My Pillow guy, alleging that he had had a “secret romance” with the actress Jane Krakowski, wooing her with flowers and champagne. Ms. Krakowski was allegedly impressed that Mr. Lindell had turned his life around, going from crack cocaine addict in his 20’s, to whatever he is now. The article mentioned that both Mr. Lindell and Ms. Krakowski denied knowing each other. Mr. Lindell sued for defamation, alleging that his supporters would be disappointed that he would have a secret relationship.

Held: Failure to plead the defendant had made defamatory statements that would hold Mr. Lindell up tp public hatred, shame, and ridicule (even if untrue). Neither Mr. Lindell and Ms. Krakowski are married, so an allegation that they are dating is not particularly scandalous. Furthermore, the target audience for the article was the general population, and, on the whole, they’re not all that worked up about this sort of thing. Mr. Lindell couldn’t define a sub-section of the audience that was the less of him in order to define the interpretation of the statement.

Mr. Lindell Has been dabbling in starting his own media company, named FRANK, so maybe it is just as well that he doesn’t help establish defamation precedents that are bad for the press.

lindell daily mirror defamation