Defamation suit from movie producer flops at 11th Circuit

ATLANTA (CN) — An 11th Circuit panel on Friday declined to revive an award-winning movie producer’s defamation suit against The Hollywood Reporter, citing jurisdictional issues and an expired statute of limitations.

John P. Middleton’s credits include “The Lego Movie” and “Manchester by the Sea." In 2022, he sued The Hollywood Reporter and writer Gary Baum in federal court in Florida over an article that claimed he solicited prostitutes, drinks heavily and suffers from obsessive-compulsive disorder. The suit also named fellow producer Roy Lee, whom Middleton accused of a “campaign of lies.”

In 2023, U.S. District Judge Jose Martinez threw out the complaint because Middleton did not respond in time to a motion to dismiss.

In his order, the George W. Bush appointee also pointed out that all defendants and claims were based in California. He noted that California law has a one-year statute of limitations for defamation cases and that Middleton filed his lawsuit more than a year after publication. Middleton, who lives in Florida, hoped to keep the case there. He appealed to the 11th Circuit, which heard oral arguments in December.

In a 24-page decision on Friday, the 11th Circuit panel agreed with the lower court that Middleton’s claims were barred by California’s statute of limitations.

“Mr. Middleton conceded in his brief and at oral argument that the conduct causing his injuries occurred in California,” wrote U.S. Circuit Judge Adalberto Jordan, a Barack Obama appointee. Florida courts look at which state the parties have the “most significant relationship" in, the panel noted.

“Although Mr. Middleton alleged that he suffered harm to his reputation and business activities in Florida … those allegations do not negate the existence of injury elsewhere,” Jordan wrote. And since “Middleton conceded in his brief and at oral argument that the conduct causing his injuries occurred in California,” the Golden State’s one-year statute of limitations applied in this case.

Middleton’s attorney Brady Williamson did not immediately respond to a request for comment.

The article at issue — written by Baum and entitled “Allegations of Prostitution, Substance Abuse and Spying: Inside Hollywood’s Nastiest Producer Feud" — chronicles a clash between Middleton and Lee over money and production credits.

The story, published in 2020, relies heavily on Lee’s accusations that Middleton harmed their shared production company by habitually drinking, using a security firm to spy on a former girlfriend and text messaging a sex worker. It also details a reported battle with obsessive-compulsive disorder that the article claims made the 41-year-old producer miss business meetings.

In addition, the article mentions donations reportedly made by Middleton to a 2016 Trump PAC that was accused of trying to suppress minority voters during that year’s election.

“Defendants falsely portray Middleton as a vote-suppressing racist, a drunk, a patron of prostitutes and having a crippling mental illness,” Middleton said in the original complaint. “None of this is true; all of it was fabricated in an effort to destroy Middleton’s reputation, career and business, because he exercised his right to enforce his legal rights against his former business associate, Lee.”

The Hollywood Reporter did not immediately respond to a request for comment on the ruling.

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