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Federal Appellate Court Revives Defamation Case Against MSNBC Host Joy Reid

Reid’s new show debuts next Monday in Chris Matthews’ former time slot

A federal appellate court revived a defamation case against Joy Reid Wednesday, vacating a lower court’s dismissal of defamation claims made by Roslyn La Liberte. The move comes just five days before the MSNBC host’s new show, “The ReidOut,” debuts in the 7 p.m. weeknight time slot.

The U.S. Court of Appeals for the Second Circuit found the dismissal erroneous, issuing a ruling vacating the decision and remanding the case.

Senior U.S. Circuit Judge Dennis Jacobs wrote the opinion, reviewed by TheWrap.

In it, Jacobs wrote, “We hold (for the first time) that California’s anti-SLAPP statute is inapplicable in federal court because it conflicts with Federal Rules of Civil Procedure 12 and 56. We also vacate the dismissal of the defamation claim under Rule 12(b)(6). As to one of the statements at issue, the court erroneously deemed La Liberte to be a limited purpose public figure (and accordingly dismissed for failure to plead actual malice); as to the other, the court mischaracterized it as nonactionable opinion. We affirm the district court’s conclusion that Reid does not qualify for immunity under section 230 of the Communications Decency Act.”

The Court recommended the case move to discovery.

La Liberte filed the original defamation lawsuit against Reid in 2018, accusing the MSNBC star of spreading a false claim that La Liberte hurled racial slurs toward a teenage boy while attending a Simi Valley, Calif., city council meeting in June of that year.

Reid latched onto a viral photo of La Liberte, wearing a MAGA hat and appearing to be engaged in a heated conversation with a hoodie-wearing boy, that went viral at the time.

But the young man, 14-year-old Joseph Luevanos, told local news that La Liberte had been “civil” and was even recorded hugging her at another moment during the meeting. Reid then posted an apology on Twitter.

MSNBC declined TheWrap’s request for comment.