Spears v. The New York Times Company

CourtDistrict Court, N.D. Alabama
DecidedOctober 7, 2025
Docket7:23-cv-00692
StatusUnknown

This text of Spears v. The New York Times Company (Spears v. The New York Times Company) 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
Spears v. The New York Times Company, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA WESTERN DIVISION

KAI SPEARS, ) ) Plaintiff ) ) vs. ) Case No. 7:23-cv-00692-ACA-HNJ ) THE NEW YORK TIMES COMPANY, ) ) Defendant )

MEMORANDUM OPINION AND ORDER This action proceeds before the court on the motion by non-party The Board of Trustees of the University of Alabama (“the Board”)1 to quash a subpoena Defendant The New York Times Company (“NYT”) issued to University of Alabama employee Shane Lyons (“Lyons”) to testify at deposition, or alternatively, for a protective order. (Doc. 112). United States District Judge Annemarie Carney Axon referred the motion to the undersigned. (Doc. 114 and August 13, 2025, docket entry). NYT opposes the motion. (Doc. 128). For the reasons set out herein, the court will DENY the motion to the extent it seeks to quash the subpoena but GRANT the motion to the extent it seeks a protective order limiting the duration of the deposition.

1 The Board filed the motion “for and on behalf of its member institution, the University of Alabama (“UA”) and, specifically, its employee Shane Lyons (“Lyons”). (Doc. 112, at 1). BACKGROUND Plaintiff Kai Spears, a former basketball player for the University of Alabama,

asserts state law claims against NYT for defamation/libel and false light invasion of privacy. (Doc. 28).2 The claims concern NYT’s reporting of a fatal shooting on January 15, 2023, in Tuscaloosa, Alabama. NYT published an article on March 15, 2023, erroneously stating Spears was present at the time of the shooting, along with two other

University of Alabama basketball players. (Id. ¶¶ 16-20, 47-48). Specifically, the NYT article contained the following statements: A fatal January shooting that involved members of the top-ranked Alabama men’s basketball team, which has loomed over the Crimson Tide as they chase a national championship, could have been even more deadly, as surveillance video showed that two players were in a car struck by bullets in the crossfire.

The shootout, which sent people nearby scrambling for cover, killed Jamea Harris, 23, who was a passenger in a car. In another car that was struck were Brandon Miller, a star player for the Crimson Tide, and Kai Spears, a freshman walk-on whose presence at the scene had not been previously reported.

. . . .

Including Spears, at least four Alabama players have now been placed at the scene of the shooting that took place in the early morning hours of Jan. 15, as bars emptied out along The Strip, a popular gathering spot for students near campus along University Boulevard in Tuscaloosa.

2 Federal diversity jurisdiction exists over the state claims, as the parties hail from different states, and the amount in controversy exceeds $75,000. (Doc. 28, ¶¶ 8-11; see 28 U.S.C. § 1332(a)(1)). 2 Jaden Bradley, a freshman guard, was also at the scene. A review of surveillance video showed his car was in a narrow lane that intersects University Boulevard, parked ahead of Miller and Spears. Behind Miller and Spears was a Jeep with Harris in the front passenger seat.

In its aftermath, the school has sought to distance itself from the shooting. . . . [T]he involvement of other players — of which the school was aware — was kept quiet . . . .

(Doc. 12-1 at 3, 4, 5). Spears, his father, and his attorney denied Spears’s presence at the scene of the shooting, yet Spears declined to provide NYT a full interview pursuant to directives from the University not to respond to media questions about the shooting. (Id. ¶¶ 52- 54, 58). After NYT published the story, it allegedly received information from multiple sources that it inaccurately reported Spears’s presence at the scene, yet it did not correct the report. (Id. ¶¶ 59-62, 67-69). On March 16, 2023, NYT reporter Billy Witz allegedly informed the Spears family the newspaper would issue a retraction only if Spears agreed to a full interview. When Spears refused, NYT issued a statement on March 17, 2023, standing by its story, and other news outlets picked up the report. (Id. ¶¶ 70-74). Eventually, on June 2, 2023, Spears agreed to provide NYT an interview. He identified Cooper Lee, the student basketball manager, as an additional individual in Miller’s car the night of the shooting. (Doc. 28, ¶¶ 77-79). After receiving that 3 information and confirming it with Cooper Lee, NYT publicly acknowledged it previously misidentified Spears as the passenger. (Id. ¶¶ 80-82).

Spears filed this lawsuit on May 30, 2023 (Doc. 1), and he amended his complaint on December 27, 2023. (Doc. 28). NYT’s Answer to the Amended Complaint asserts affirmative defenses, including that “[s]ome or all allegedly defamatory statements or implications about Plaintiff are true or substantially true, and Plaintiff

cannot carry his burden of proving that any such statement or implication is materially false,” and “[s]ome or all of the statements at issue are not reasonably capable of the defamatory meaning attributed to them by Plaintiff.” (Doc. 30, at 17).

On July 31, 2025, NYT served a non-party subpoena seeking to depose Lyons, the University of Alabama Executive Deputy Director of Athletics and Chief Operating Officer. The Board did not attach a copy of the subpoena to its motion, but it states that NYT’s attorneys have represented they primarily seek

Lyons’ testimony regarding 1) Lyons’ conversations with Christian Spears [Kai Spears’s father] following the incident underlying this case, although it is UA’s understanding that Christian Spears has been deposed by NYT, and 2) meetings that occurred between UA officials and members of UA’s men’s basketball team to provide information for its “substantial truth” affirmative defense.

(Doc. 112, at 2). The Board challenges the subpoena on the grounds that the information NYT seeks from the deposition does not bear relevance to any party’s claims or defenses, 4 and the information sought duplicates information NYT already sought from another University official in a prior deposition.

DISCUSSION Pursuant to Federal Rule of Civil Procedure 45, “[a] party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena.” Fed. R. Civ. P. 45(d)(1).

The district court may quash or modify a subpoena that “subjects a person to undue burden.” Fed. R. Civ. P. 45(d)(3)(A)(iv). See BMO Harris Bank, N.A. v. Richert Funding, LLC, No. 1:15-CV-3886-AT, 2017 WL 11627485, at *10 (N.D. Ga. July 3, 2017)

(citations omitted) (The subpoena issuer’s duty to avoid undue burden or expense on the receiving party “‘reflects a balancing between the litigants’ need to obtain information from non-parties and the need to protect outsiders to the litigation from having to incur undue burden and expense.’”).

“While Rule 45 does not specifically identify irrelevance as a reason to quash a subpoena, it is generally accepted that the scope of discovery allowed under Rule 45 is limited by the relevancy requirement of the federal discovery rules.” Jordan v. Comm’r, Mississippi Dep’t of Corr., 947 F.3d 1322, 1329 (11th Cir. 2020) (citing Fed. R. Civ. P.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Michael D. Van Etten v. Bridgestone/Firestone, Inc
263 F.3d 1304 (Eleventh Circuit, 2001)
Masson v. New Yorker Magazine, Inc.
501 U.S. 496 (Supreme Court, 1991)
Mead Corp. v. Hicks
448 So. 2d 308 (Supreme Court of Alabama, 1983)
Wal-Mart Stores, Inc. v. Smitherman
872 So. 2d 833 (Supreme Court of Alabama, 2003)
Richard Jordan v. Georgia Department of Corrections
947 F.3d 1322 (Eleventh Circuit, 2020)
Higgs v. Bole
103 So. 3d 40 (Supreme Court of Alabama, 2012)
Adams v. Bank of America, N.A.
237 F. Supp. 3d 1189 (N.D. Alabama, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Spears v. The New York Times Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spears-v-the-new-york-times-company-alnd-2025.