Turntine v. Peterson, No. 19-2185 (8th Cir. 2020)Annotate this Case
The Eighth Circuit reversed the district court's dismissal of plaintiffs' complaint alleging three defamation counts against defendants. The defamatory statements at issue stemmed from the parties' failed business relationship in the sport of darts.
The court held that the pleaded actual damages are sufficient to satisfy the $75,000 amount-in-controversy requirement. In this case, the complaint does not limit its request for damages to a precise monetary amount, but pleaded in excess of $60,000. On the merits, the court held, under Missouri law, that defendants' three statements are capable of defamatory meaning and the opinion privilege does not render these statements nonactionable at this stage. In light of the totality of the circumstances and context in which these statements were made, the court held that a reasonable factfinder could conclude that these statements at a minimum imply an assertion of objective fact. Therefore, the district court erred in concluding that the complaint failed to state a claim for defamation and in dismissing the action. The court remanded for further proceedings.