In a decision filed June 13, 2016, the United States Court of Appeals for the 8th Circuit overturned the verdict in favor of Jesse Ventura against Chris Kyle’s estate. Kyle is a former SEAL regarded as the deadliest sniper in U.S. history and author of the bestselling book American Sniper. Ventura sued Kyle under Minnesota law for defamation, misappropriation and unjust enrichment. The jury returned an award of $500,000 in damages on the defamation claim and $1.35 million on the unjust enrichment claim.
The late author Kyle, in his book American Sniper: The Autobiography of the Most Lethal Sniper in U.S. Military History, referenced an altercation in a bar in California where Kyle and some friends had gathered after the funeral of a fellow SEAL. According to Kyle, “Scruff Face,” a former SEAL was mouthing off at the bar. Kyle approached Scruff and asked him to “cool it.” Kyle claims Scruff swung at him. Kyle punched him and “laid him out.” Kyle was interviewed on the radio and television program “The O’Reilly Factor” to promote his book during which Kyle named “Scruff Face” as being Jesse Ventura.
The 8th Circuit Court reversed the defamation judgment and remanded the claim for a new trial. The Court reversed the unjust-enrichment judgment, noting such a claim did not exist under Minnesota law.
The defamation claim was reversed based on references to insurance coverage made throughout the trial and closing arguments. While Rule 411 of the Federal Rules of Evidence allows evidence of insurance on a limited basis to prove bias, the Court of Appeals determined the trial court erred in allowing references to the insurance and found it was prejudicial error to admit the evidence. It prevented Kyle from receiving a fair trial.
This webpage contains general information and not legal advice. It is based on Minnesota law in effect at the time of writing. An attorney at Farrish Johnson can advise you about how the law applies to your specific situation.