The appeals court agrees that the makers of WolfOfWallStreet 'took appropriate steps to ensure that no one would be defamed by the Film,'
The 2nd Circuit tackles a "libel-in-fiction" claim, holding no actual malice because among other things, the producers used fake names and included a disclaimer.didn't recklessly make false statements in the 2013 Martin Scorsese film about Andrew Greene, former executive at the disgraced brokerage firm Stratton Oakmont. As a result, Greene won't be able to revive his libel suit.all the way back in 2014.
"While this Court has not spoken definitively on defamation in the context of fictitious characters, our First Amendment jurisprudence requires a plaintiff to show both that the character is similar enough to him to be 'of and concerning' him, and that the portrayal is false and defamatory," writes a unanimous three-judge panel at the 2nd Circuit.
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