Drummond Company, Inc. et al. v. Terrence P. Collingsworth et al.

CourtDistrict Court, N.D. Alabama
DecidedJune 2, 2026
Docket2:11-cv-03695
StatusUnknown

This text of Drummond Company, Inc. et al. v. Terrence P. Collingsworth et al. (Drummond Company, Inc. et al. v. Terrence P. Collingsworth et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Drummond Company, Inc. et al. v. Terrence P. Collingsworth et al., (N.D. Ala. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

DRUMMOND COMPANY, INC. et al., } } Plaintiffs, } } v. } } Case No.: 2:11-cv-3695-RDP TERRENCE P. COLLINGSWORTH, } et al., } } Defendants. } }

DRUMMOND COMPANY, INC., et al., } } Plaintiffs, } } v. } } Case No.: 2:15-cv-506-RDP TERRENCE P. COLLINGSWORTH, et } al., } } Defendants. } }

MEMORANDUM OPINION Before the court are Defendants Terrence P. Collingsworth and International Rights Advocates Inc.’s Motions for Judgment as a Matter of Law (Defamation Case, Doc. # 1243; RICO Case, Docs. # 754, 755).1 The Motions have been fully briefed, (Defamation Doc. # 1248, 1251; RICO Docs. # 758, 759, 762, 763), and are ripe for decision. After careful review, and for the reasons explained below, Defendants’ Motions are due to be denied.

1 For brevity and ease of citation, the court refers to documents filed in Case No.: 2:11-cv-3695-RDP as Defamation and Case No.: 2:15-cv-506-RDP as RICO. In reviewing a motion for judgment as a matter of law under Federal Rule of Civil

Procedure 50, the court draws all reasonable inferences in favor of the non-moving party, does not re-weigh the evidence presented to the jury or make any credibility determinations, and disregards any “evidence that the jury need not have believed.” Chmielewski v. City of St. Pete Beach, 890 F.3d 942, 948 (11th Cir. 2018); see also Reeves v. Sanderson Plumbing Prod., Inc., 530 U.S. 133, 151 (2000) (“[T]he court should give credence to the evidence favoring the nonmovant as well as that evidence supporting the moving party that is uncontradicted and unimpeached, at least to the extent that that evidence comes from disinterested witnesses.”) (cleaned up). The “court’s sole consideration of the jury verdict is to assess whether that verdict is supported by sufficient evidence.” Chaney v. City of Orlando, 483 F.3d 1221, 1227 (11th Cir. 2007). In considering the sufficiency of the evidence, “‘the court must evaluate all the evidence,

together with any logical inferences, in the light most favorable to the non-moving party.’” McGinnis v. Am. Home Mortg. Servicing, Inc., 817 F.3d 1241, 1254 (11th Cir. 2016) (quoting Beckwith v. City of Daytona Beach Shores, 58 F.3d 1554, 1560 (11th Cir. 1995)). A court should only “‘render judgment as a matter of law when there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue.’” Progressive Emu Inc. v. Nutrition & Fitness Inc., 787 F. App’x 549, 556 (11th Cir. 2019) (first quoting Gowski v. Peake, 682 F.3d 1299, 1310- 11 (11th Cir. 2012), in turn citing Fed. R. Civ. P. 50)); see also Brown v. Ala. Dep’t of Transp., 597 F.3d 1160, 1173 (11th Cir. 2010) (“Under Federal Rule of Civil Procedure 50, judgment as a matter of law is appropriate only if the facts and inferences point [so] overwhelmingly in favor of

one party . . . that reasonable people could not arrive at a contrary verdict.”); Christopher v. Florida, 449 F.3d 1360, 1364 (11th Cir. 2006) (holding that the court must deny a motion for judgment as a matter of law “if there is substantial conflict in the evidence, such that reasonable 2 “District courts seldom enter a judgment as a matter of law, for it is appropriate only when

there can be but one reasonable conclusion as to the verdict.” Thomas v. Broward Cnty. Sheriff’s Off., 71 F.4th 1305, 1312 (11th Cir. 2023) (cleaned up). That is, “[j]udgment as a matter of law is appropriate only if the facts and inferences point overwhelmingly in favor of one party, such that reasonable people could not arrive at a contrary verdict.” Luxottica Group, S.p.A. v. Airport Mini Mall, LLC, 932 F.3d 1303, 1310 (11th Cir. 2019) (cleaned up). The court may “not second-guess the jury or substitute [its] judgment for [the jury’s] judgment if [the jury’s] verdict is supported by sufficient evidence.” Tracy v. Fla. Atl. Univ. Bd. of Trs., 980 F.3d 799, 811 (11th Cir. 2020) (cleaned up). With these legal standards in mind, the court considers the merits of each of Defendants’ motions below. II. Analysis

The court separately addresses the respective Rule 50 Motions filed by Collingsworth and IRAdvocates. After careful review, the court concludes each motion is due to be denied. A. Defendant Terrence P. Collingsworth’s Rule 50 Motion for Judgment as a Matter of Law Collingsworth argues he is entitled to judgment as a matter of law because (1) Drummond failed to present sufficient evidence from which a jury could find that he acted with actual malice, a required element of Drummond’s defamation claim, and (2) Drummond failed to present sufficient evidence to support the jury’s finding that he violated RICO. (Defamation Doc. # 1243; RICO Doc. # 754). The court considers each argument, in turn. Neither succeeds. 1. Drummond presented more than sufficient evidence of actual malice Collingsworth first argues he is entitled to judgment as a matter of law because Drummond failed to present sufficient evidence – that is, clear and convincing evidence – from which a jury

3 whether Collingsworth is entitled to Judgment as a Matter of Law, the court must determine

whether the jury’s verdict against Collingsworth is “supported by sufficient evidence.” Chaney, 483 F.3d at 1227. The Supreme Court has explained that “the actual malice standard is not satisfied merely through a showing of ill will or ‘malice’ in the ordinary sense of the term.” Harte-Hanks Commun., Inc. v. Connaughton, 491 U.S. 657, 666-67 (1989) (citing Beckley Newspapers Corp. v. Hanks, 389 U.S. 81 (1967) (per curiam); Henry v. Collins, 380 U.S. 356 (1965) (per curiam)). Rather, as one deemed a public figure for purposes of this litigation, Drummond was required to prove by clear and convincing evidence that Collingsworth acted with “reckless disregard” of the truth. Id. While the term “reckless disregard” “cannot be fully encompassed in one infallible definition,” St. Amant v. Thompson, 390 U.S. 727, 730 (1968), the Supreme Court has made clear that the

defendant must have made the false publication with a “high degree of awareness of . . . probable falsity,” Garrison v. Louisiana, 379 U.S. 64, 74 (1964), or must have “entertained serious doubts as to the truth of his publication,” St. Amant, 390 U.S. at 731. Collingsworth’s motion is focused on his subjective state of mind, specifically his “subjective belief that Drummond was collaborating with the AUC.” (Defamation Doc. # 1243 at 11). But, as this court already explained in denying Collingsworth’s first Rule 50 motion, “Drummond presented significant evidence from which a jury could conclude that [Collingsworth] acted with actual malice.” (Defamation Doc. # 1188 at 2).

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Drummond Company, Inc. et al. v. Terrence P. Collingsworth et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/drummond-company-inc-et-al-v-terrence-p-collingsworth-et-al-alnd-2026.