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Eleventh Circuit Rules Golfer's Defamation Appeal Is Out-of-Bounds

Kit Yona, M.A.

Article by: Kit Yona, M.A.

Legal Writer

Reviewed by Joseph Fawbush, Esq. | Last updated on

Well, at least they can't take his green jacket away.

Professional golfer Patrick Reed, who was strongly criticized for leaving the PGA Tour to join LIV Golf in 2022, felt that some of the condemnation he received crossed a line. He brought lawsuits against the Golf Channel, several of its commentators, and other members of the media. Claiming the attacks against him had cost him numerous endorsements, his two suits alleging 36 defamation counts sought relief in excess of $1 billion.

The Eleventh Circuit Court of Appeals ruled that Reed had overshot the green, upholding the previous ruling of a Florida district court judge. On July 8, 2025, a three-judge panel dismissed Reed's suit with prejudice, agreeing that the golfer had failed to prove any actual malice by those who took him to task for moving to LIV Golf.

Reed's suit was part of the ongoing saga between the PGA Tour and LIV Golf, which included an antitrust lawsuit that ended with a "framework" to unite the leagues that has not been realized yet. While the legal battle between the two golf empires might not be over, Reed finds himself with few legal options remaining.

You'll Get Nothing and Like It

The emergence of a new professional league in 2021 rocked the golfing world. LIV Golf, created and controlled by Crown Prince Mohammed bin Salman through Saudi Arabia’s Public Investment Fund, positioned itself to compete with the one and only king of professional golfing, the PGA Tour.

Salman's role in LIV became an instant source of controversy, as he'd been accused of running an authoritarian regime and ordering the murder of journalist Jamal Khashoggi. LIV Golf began luring PGA Tour golfers away with increased prize pools, fewer required tournaments, and no cut-off point for competitors during an event.

The PGA Tour responded by suspending golfers who signed with LIV Golf and banning them from competing in PGA Tour events. LIV Golf countered by filing an antitrust suit against the PGA Tour in 2023. This was leveraged into a settlement designed to bring the two entities together in 2023. While a framework was set in place, the two sides do not currently appear to be even remotely close to any sort of working agreement.

The LIV Golf wooing included Reed, a winner of the prestigious Masters Tournament in 2018. Jumping ship in 2022, Reed found himself facing heavy backlash from members of the golf media world, including commentators on the Golf Channel. Brandel Chamblee, who was named as one of the defendants, wondered out loud whether, if Reed was willing to play for someone like Salman, he would also have been okay with playing for other historical monsters such as Hitler, Pol Pot, or Vladimir Putin. Other journalists accused Reed and other golfers who switched to LIV Golf of having "opted to cut and run for Saudi money."

In his suits, Reed alleged defamation, defamation per se, defamation by implication, and tortious interference of contract by the defendants. He claimed that his endorsement contracts and potential deals with major companies like Nike, DraftKings, and Titleist were either not renewed or not offered after the waves of damaging defamation by those named in the suits. He estimated his loss at least $1 billion.

Right in the Lumberyard

Reed's first attempt to file his lawsuits was categorized as "shotgun pleadings" by a Florida trial judge and dismissed without prejudice. The amended complaints were met with motions to dismiss by the defendants under Federal Rule of Civil Procedure 12(b)(6). The judge agreed that Reed had failed to prove any of the defendants had acted with actual malice. The court dismissed the suits with prejudice, prompting Reed to seek relief through an appeal.

The panel from the Eleventh Circuit Court of Appeals was also unmoved by Reed's accusations of actual malice. They agreed that he hadn't met the standard for proving that the defendants defamed him with malice or deliberately evaded the truth.

With the Eleventh Circuit affirming the ruling of dismissal with prejudice, Reed's options with these suits are limited. He can petition the Eleventh Circuit for an en banc appeal, but the chances of that being granted are likely slim. He can also petition to be heard by the U.S. Supreme Court.

Reed may not have gotten his $1 billion legal payday, but he's probably not going to have to resort to living in the assistant greenskeeper's shed anytime soon. In 2024, he earned over $5 million on the LIV Golf tour.

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