Minnesota's Court of Appeals Delivers Initial UPEPA Ruling in Dalvin Cook's Legal Matter
Dalvin Cook, a NFL player for the Minnesota Vikings, found himself embroiled in a series of legal battles. In 2020, a personal injury lawsuit was filed against him by Daniel Cragg and Anne St. Amant on behalf of Gracelyn Trimble, who was allegedly injured in an altercation. The case was settled in 2024.
However, in 2021, things took an unexpected turn when Cook sued Cragg, St. Amant, and their law firm, Eckland & Blando, LLP, in Hennepin County, Minnesota. Cook accused them of defaming him by providing unfiled and unserved complaints to the media, allegedly painting him as having inflicted serious physical harm to Trimble. He also claimed defamatory statements were made public record by the defendants filing an unsealed memorandum as part of the settlement negotiations.
For several years, this litigation continued, with the defendants filing motions and Cook filing amended complaints. In 2024, Minnesota adopted the Uniform Public Expression Protection Act ("UPEPA") as its Anti-SLAPP law. This development allowed the defendants to bring a UPEPA special motion to dismiss Cook's lawsuit.
The Hennepin County judge overruled the special motion, leading the defendants to appeal. This case, known as Cook v. Trimble, is the first Minnesota opinion to consider the Minnesota UPEPA.
The Minnesota Court of Appeals, in a fresh look at the merits of the defendants' UPEPA special motion, first recognized the existence of a judicial-proceedings privilege. This privilege protects statements made by judicial officers, parties, or their counsel, within the judicial proceeding, and relevant to the subject matter of the litigation.
The problem for the defendants was that their media statements were not made within the judicial proceeding of the Hennepin County action, making them vulnerable to defamation claims. On the other hand, the memorandum filed with the Hennepin County court was protected by this privilege since all its elements were satisfied.
While the media statements were not privileged, they didn't automatically mean that Cook had a strong case for defamation against the defendants. To survive dismissal, Cook needed to present clear and convincing evidence that the defendants acted with malice in making the media statements. However, the Court of Appeals found that Cook had not met this burden.
Cook also had an invasion of privacy claim based on the defendants' statements. The Court of Appeals held that Cook had made a prima facie case for this claim and the UPEPA special motion was not granted as to this claim.
In the end, the Court of Appeals reversed the Hennepin County court's decision as to the media statements and the memorandum, holding that the UPEPA special motion should have been granted for those claims. However, the Court of Appeals also affirmed the denial of the UPEPA special motion as to Cook's invasion of privacy claim and remanded the case back to the Hennepin County court for further litigation.
This ruling is a significant step in Minnesota's efforts to protect free speech and related rights through the UPEPA. The UPEPA special motion provided an immediate appeal of right to the Minnesota Court of Appeals for the defendants, allowing them to quickly rectify the Hennepin County judge's ruling and focus on the viable invasion of privacy claim. The uniformity provision in the UPEPA helped the Court of Appeals determine how the UPEPA should be applied by considering decisions from other states that have adopted the UPEPA.
- Dalvin Cook, despite facing legal battles in the NFL related to a personal injury lawsuit in 2020, also pursued a defamation case against others in 2021, claiming they provided unfiled and unserved complaints to the media, defaming him.
- In the 2021 litigation, Cook's case involved statements made outside of the judicial proceeding in Hennepin County, Minnesota, and he needed to present clear and convincing evidence of malice to survive dismissal, a burden he failed to meet.
- On a separate note, the WNBA, NBA, and NCAA-Basketball are popular sports leagues in the United States, distinct from the legal battles encountered by Dalvin Cook in the world of sports and law.
