Sackler v. American Broadcasting Cos., Inc.

2024 NY Slip Op 33092(U)
CourtNew York Supreme Court, New York County
DecidedSeptember 4, 2024
DocketIndex No. 155513/2019
StatusUnpublished
Cited by1 cases

This text of 2024 NY Slip Op 33092(U) (Sackler v. American Broadcasting Cos., Inc.) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sackler v. American Broadcasting Cos., Inc., 2024 NY Slip Op 33092(U) (N.Y. Super. Ct. 2024).

Opinion

Sackler v American Broadcasting Cos., Inc. 2024 NY Slip Op 33092(U) September 4, 2024 Supreme Court, New York County Docket Number: Index No. 155513/2019 Judge: W. Franc Perry Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 155513/2019 NYSCEF DOC. NO. 136 RECEIVED NYSCEF: 09/04/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. W. FRANC PERRY PART Justice ---------------------------------------------------------------------------------X INDEX NO. 155513/2019 DAVID SACKLER, MOTION DATE 03/29/2022 Plaintiff, MOTION SEQ. NO. 003 -v- AMERICAN BROADCASTING COMPANIES, INC.,HOME BOX OFFICE, INC.,NYP HOLDINGS, INC.,THOMPSON REUTERS D/B/A REUTERS AMERICA LLC,HEARST DECISION + ORDER ON MAGAZINES A DIVISION OF HEARST MOTION COMMUNICATIONS, INC.

Defendant. ---------------------------------------------------------------------------------X

The following e-filed documents, listed by NYSCEF document number (Motion 003) 68, 69, 70, 71, 72, 73, 74, 75, 76, 98, 99, 100, 105, 106, 108, 110, 111, 134 were read on this motion to/for RENEWAL .

This Court previously granted the plaintiff’s, David Sackler, motion to renew. See

NYSCEF Doc. No. 134. Upon granting such renewal, the Court will now decide the choice of

law issue at the heart of the defendant’s, NYP HOLDINGS, INC., underlying motion to dismiss,

motion sequence 002, seeking dismissal of the plaintiff’s amended complaint.

Plaintiff brought this action for libel per se/slander per se and defamation per/se against

multiple defendants. The action is based on the defendants’ mistaken use of a photograph and

sketch of the plaintiff, David Sackler, while reporting on the OxyContin endemic. The plaintiff is

not the David Sackler of the Sackler family and Purdue Pharma. The defendant, NYP

HOLDINGS, INC., publishes the “N.Y. Post” which is a daily publication that is available

worldwide in hard copy and online editions. See NYSCEF Doc. 26 ¶ 49.

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While this matter was pending, the New York Legislature amended the “anti-SLAPP

(strategic lawsuits against public participation)” law which is codified at New York Civil Rights

Law §70-a, §76-a, to now require a plaintiff, whether a public or private figure, to prove actual

malice on the part of the defendant in the communication that gave rise to the action.

This Court agreed with prior federal rulings and found that the New York Legislature

intended its 2020 amendments to New York Civil Rights Law §70-a, §76-a to apply

retroactively. (See NYSCEF Doc. No. 58; Palin v. New York Times Co. 510 F.Supp.3d 21 (2020)

and Coleman v. Grand 523 F.Supp.3d 244 (2021).

The parties requested this Court to hold the petitioner’s motion to renew in abeyance as

the issue of whether the New York Legislature’s amendments to §76-a should be retroactively

applied was pending before the New York Court of Appeals in the matter of Gottwald v. Sebert,

40 N.Y.3d 240 (2023). See NYSCEF Doc. No. 108.

Gottwald v. Sebert

The First Department decided that the 2020 amendments to the anti-SLAPP were to

apply prospectively not retroactively, including the requirement for a plaintiff to prove actual

malice. See Gottwald v. Sebert, 203 A.D.3d 488 (1st Dept. 2022). The Court of Appeals

overturned the First Department on the application of attorney’s fees and whether the plaintiff,

Gottwald, in that case was a limited public figure. See Gottwald v. Sebert, 40 N.Y.3d 240 (N.Y.

Court of Appeals 2023). The Court of Appeals found that while the defendant could not recover

attorney’s fees retroactively, the defendant could recover costs, attorney's fees, and damages

from the continuation of the action after the effective date of the statutory amendments and the

calculation of such damages would be from the effective date of the amendments. See Id. at 258-

59. The Court did not decide whether the provision of the amended statute (Civil Rights Law §

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76-a [2]) requiring a showing that the allegedly defamatory statements were made with actual

malice was to apply to actions pending after the effective date of the amendments as it disagreed

with the First Department and found that the plaintiff, Gottswald, was in fact a limited public

figure thus the actual malice standard already applied to him. Id. at 257.

Based on the First Department’s and Court of Appeals’ rulings and reasoning in

Gottswald, this Court granted the plaintiff’s motion to renew finding that the actual malice

standard was not to be applied retroactively to this matter which was filed prior to the enactment

of the statutory amendments. See NYSCEF Doc. No. 134. In granting the defendant’s

underlying motion to dismiss, this Court did not decide whether New Jersey or New York law

applied to this action, the Court instead determined the actual malice requirement was to apply

retroactively and thus the standard between the two states was the same and the plaintiff’s

allegations were legally insufficient to show actual malice by the defendant. See NYSCEF Doc.

No. 58. Upon granting renewal, the Court will now determine whether New York or New Jersey

defamation law should apply to this dispute.

Facts ---- Mr. Sackler is a resident of the state of New Jersey. See NYSCEF Doc. No. 36 at ¶ 23.

The N.Y. Post has its primary place of business in the state of New York where it produces a

national daily publication that is available worldwide in both hard copy and online editions. See

NYSCEF Doc. ¶¶ 47 & 49. Plaintiff alleges that the N.Y. Post used a photo of him instead of

the David Sackler of Purdue Pharma in an online article about the Sackler family of Purdue

Pharma published on May 12, 2019. See NYSCEF Doc. No. 6 Am. Complaint at ¶ 111-15. Mr.

Sackler notes that the photograph utilized by the Post he is holding a bottle of Trimwater, a

beverage distributed by his company, Lifestyles Beverages, Inc. Id. at ¶ 116. The Post’s story

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also ran in its printed edition which featured the same photograph but had been cropped and did

not show the beverage from the plaintiff’s company. Id. at 119. Mr. Sackler also alleges

reputational harm when the N.Y. Post published a different picture of him again holding a bottle

of Trimwater in a May 15, 2019 online article entitled “Met to reject gifts from the Sacklers amid

the fury over the opioid crisis”. Id. at ¶ 126-130. The hardcopy version of this article did not

include a photograph. Id. at ¶ 132.

Mr. Sackler cites specific examples of reputational harm that occurred in California,

Florida, New Jersey and New York due to the defendant’s use of his photograph when reporting

on the opioid crisis. Id. at ¶ ¶ 142-45 & 149. Mr. Sackler also points to phone calls and a

Facebook message received from people in Maryland, Michigan and Texas regarding the use of

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Sackler v. American Broadcasting Cos., Inc.
2024 NY Slip Op 33092(U) (New York Supreme Court, New York County, 2024)

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