In Farrakhan v. Anti-Defamation League, (SD NY, April 5, 2024), a New York federal district court dismissed defamation claims asserted by Louis Farrakhan against the Anti-Defamation League. The court describes Farrakhan's allegations:
The [complaint], which details nearly a century's worth of grievances, alleges several instances of defamation and, as against the ADL, various violations of the plaintiffs' First Amendment rights. At their core, plaintiffs' claims are that by repeatedly referring to plaintiffs as antisemitic, defendants have defamed them and created a chilling effect on their religious practices. Plaintiffs seek $4.8 billion in damages as well as a declaratory judgment that the term "anti-Semite" is defamatory per se and that the ADL is a quasi-governmental actor that violated plaintiffs' First Amendment rights. Plaintiffs also seek to enjoin defendants from calling them antisemitic or taking any steps to urge third parties to disassociate with them.
A number of claims were dismissed on standing grounds, finding that Farrakhan did not allege concrete injuries traceable to ADL. Farrakhan's defamation claims were dismissed because Farrakhan, a public figure, did not plead actual malice. Others were dismissed because they were merely statements of opinion or Farrakhan had not alleged facts showing falsity.
