Spacecon Specialty Contractors v. Bensinger, No. 11-1139 (10th Cir. 2013)
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Richard Bensinger produced and screened a film about Spacecon Specialty Contractors, LLC. Claiming the film conveyed several defamatory statements, Spacecon filed suit against Bensinger in federal district court based on diversity jurisdiction, and asserting a state-law claim for defamation per se. The district court granted Bensinger's motion for summary judgment, concluding the messages conveyed by the film involved matters of public concern and Spacecon did not show Bensinger published the film with actual malice. Finding no abuse of the district court's discretion, the Tenth Circuit affirmed.
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