In One for Israel v. Reuven,(SD FL, Sept. 26, 2022), a Florida federal district court in a defamation case held that Messianic Jewish missionaries are not necessarily "limited public figures" who must prove "actual malice" to succeed in a defamation suit. Refusing to dismiss the suit, the court held that the theological conflict between Judaism and Christian missionaries is not a public controversy. At issue in the case was a YouTube video in which defendant, an Orthodox Jewish rabbi, claimed that the missionaries beat up another rabbi at a meeting with an individual who was considering converting to Messianic Judaism. The court also rejected the claim that the ecclesiastical abstention doctrine requires dismissal of the suit. The court said in part:
The statements said in the video have nothing to do with religion; they were about a violent attack that did not happen. These issues have nothing to do with religious doctrine or conflict.
Volokh Conspiracy has more on the decision.
