Law Offices of David Freydin v. Victoria Chamara, No. 18-3216 (7th Cir. 2022)Annotate this Case
In 2017, Freydin, a Chicago lawyer, posed a question on Facebook: “Did Trump put Ukraine on the travel ban list?! We just cannot find a cleaning lady!” After receiving online criticism for the comment, Freydin doubled down. People angered by Freydin’s comments went to his law firm’s Facebook, Yelp, and Google pages and left reviews that expressed their negative views of Freydin. Various defendants made comments including: An “embarrassment and a disgrace to the US judicial system,” “unethical and derogatory,” “hypocrite,” “chauvinist,” “racist,” “no right to practice law,” “not professional,” “discriminates [against] other nationalities,” do not “waste your money.,” “Freydin is biased and unprofessional attorney,” “terrible experience,” “awful customer service,” “disrespect,” and “unprofessional[ism].” None of the defendants had previously used Freydin’s legal services.
The Seventh Circuit affirmed the dismissal of Freydin’s suit, which alleged libel per se, “false light,” tortious interference with contractual relationships, tortious interference with prospective business relationships, and civil conspiracy. None of the reviews contained statements that are actionable as libel per se under Illinois law; each was an expression of opinion that could not support a libel claim. Freyding did not link the civil conspiracy claims to an independently viable tort claim.