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Defamation suits are often tricky. When examining them, we tend to ask if the statements are true and if they damage a person's reputation. What doesn't come up as often is whether a person's reputation is already too damaged to save.
Former MLB player Lenny Dykstra filed suit against his former New York Mets teammate, Ron Darling, last year over statements made in Darling's book "108 Stitches: Loose Threads, Ripping Yarns, and the Darndest Characters From My Time in the Game."
But when the case was examined by a New York Supreme Court judge, Dykstra's history of vitriol against, well, just about everyone, came back to haunt him.
Darling's book discusses an incident during the 1986 World Series, where Dykstra shouted a series of racist taunts at opposing pitcher Dennis "Oil Can" Boyd.
"I don't want to be too specific here, because I don't want to commemorate this dark, low moment in Mets history in that way," Darling writes. "But I will say that it was the worst collection of taunts and insults I'd ever heard..."
He goes on to describe the long tradition of "bench-jockeying" in baseball, where players tended to trash-talk one another from the bench. But those taunts generally had limits, Darling says: "This stuff coming out of Lenny's mouth was beyond the pale. Unprintable, unmentionable, unforgettable."
In his complaint, Dykstra claimed the reference "forever branded" him as a racist and tarnished the New York Mets' 1986 World Series Championship. But, according to New York Judge Robert Kalish, to be defamed, you have to have some reputation left to lose.
Judge Kalish found that Dykstra was a "libel-proof plaintiff," someone whose reputation is so poor that they cannot suffer further damage by a false statement.
"Dykstra was infamous for being, among other things, racist, misogynist, and anti-gay," Judge Kalish wrote, "as well as a sexual predator, a drug-abuser, a thief, and an embezzler."
Because readers of Darling's book were likely to already know all of this, Judge Kalish found that the book had not exposed Dykstra to any further public contempt. Given Dykstra's history of mean-spirited behavior toward women, racial minorities, and the LGBTQ community, the court found that - as a matter of law - Darling's account of the '86 World Series could not "induce an evil opinion" of Dykstra.
That evil opinion, as Judge Kalish wrote, has long existed.