Ventura v. Kyle, No. 14-3876 (8th Cir. 2016)
Annotate this CaseJesse Ventura filed suit against Chris Kyle under Minnesota law for defamation, misappropriation, and unjust enrichment. Kyle was a sniper for a United States Navy SEAL team, and, before his death, he authored the book "American Sniper: The Autobiography of the Most Lethal Sniper in U.S. Military History" (American Sniper). Kyle, before his death, referred to a celebrity, "Scruff Face," in his book who made offensive remarks about the SEALs at a gathering following the funeral of a SEAL killed in combat. Kyle later revealed that "Scruff Face" was Ventura. The jury found in favor of Ventura on the defamation claim, awarding him $500,000 in damages, and found in Kyle's favor on the misappropriation claim. On appeal, Kyle challenged the district court’s denial of his motion for judgment as a matter of law or a new trial. The court concluded that Ventura’s counsel’s closing remarks, in combination with the improper cross-examination of two witnesses about Kyle’s insurance coverage, prevented Kyle from receiving a fair trial. Therefore, the district court clearly abused its discretion in denying a new trial. The court reversed and remanded as to the defamation claim. The court rejected Ventura's unjust-enrichment theory where the claim was not allowed by Minnesota law and where there is an adequate remedy at law available. Therefore, the court vacated and remanded as to the defamation claim.
Court Description: Riley, Author, with Smith and Shepherd, Circuit Judges] Civil case - Defamation. In action by the former governor of the state of Minnesota against the estate of Chris Kyle, author of American Sniper, alleging Kyle had defamed him by fabricating an incident at a bar in which Kyle claimed to have knocked Ventura to the floor in a fight, the jury's $500,000 award to Ventura on his defamation claim is set aside and remanded for a new trial as the court erred in permitting Ventura to put prejudicial information before the jury by questioning Kyle's publisher regarding insurance and the payment of the estate's legal fees and by arguing these matters in his closing argument; the equitable remedy of undue enrichment was not available to Ventura because there was an adequate remedy at law - money damages for defamation - and the estate was entitled to judgment on the claim; the jury's $1.3 million award on the unjust enrichment claim is vacated. Judge Smith, concurring in the reversal of the unjust-enrichment judgment and dissenting from the reversal of the defamation judgment.
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