John P. Middleton v. The Hollywood Reporter LLC
137 F.4th 1287
11th Cir.2025Background
- John Middleton and Roy Lee had a professional and personal relationship primarily centered in California, which ended badly, resulting in litigation in California.
- During their legal dispute, The Hollywood Reporter published an article in June 2020 that contained allegedly defamatory statements about Middleton, including claims related to prostitution and undisclosed political donations.
- Middleton, residing in Florida at the time of publication, filed a defamation action in the Southern District of Florida against Lee, The Hollywood Reporter, and the article's author.
- The district court dismissed the claims as time-barred, holding that California's one-year statute of limitations applied per Florida's borrowing statute and choice-of-law principles.
- Middleton sought to amend his complaint to emphasize his Florida domicile and argued for application of Florida’s two-year statute of limitations, but the district court denied leave as futile.
- On appeal, the Eleventh Circuit considered whether California or Florida law applied to the statute of limitations and affirmed dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which state’s statute of limitations applies | Florida law applies due to his Florida domicile and alleged injury in Florida. | California law applies due to the parties' relationship and alleged conduct being centered in California. | California’s one-year statute of limitations applied. |
| Application of the Florida borrowing statute | Lawsuit not time-barred under Florida’s longer period. | Florida’s borrowing statute requires use of California's limitations period. | Borrowing statute applies; bars Middleton’s claims. |
| Whether amended complaint would be futile | Amendment would clarify facts favoring application of Florida law. | Amended facts do not change the most significant relationship analysis. | Amendment would be futile; leave to amend denied. |
| Appropriateness of dismissal by default | Dismissal for failure to respond was too harsh. | Within the court’s discretion to dismiss for procedural default. | Even assuming abuse, claims fail on the merits. |
Key Cases Cited
- EEOC v. Catastrophe Mgmt. Sols., 852 F.3d 1018 (11th Cir. 2016) (allowed consideration of proposed amended complaint on review of dismissal)
- Grupo Televisa, S.A. v. Telemundo Commc’ns Grp., Inc., 485 F.3d 1233 (11th Cir. 2007) (explained federal courts follow forum state’s conflict-of-law rules)
- Green Leaf Nursery v. E.I. DuPont De Nemours & Co., 341 F.3d 1292 (11th Cir. 2003) (sets standard for review of denial of leave to amend)
- Judge v. Am. Motors Corp., 908 F.2d 1565 (11th Cir. 1990) (elaborates on Florida’s conflict-of-law rule in diversity cases)
- Bates v. Cook, Inc., 509 So. 2d 1112 (Fla. 1987) (established Florida’s use of the "most significant relationship" test for tort statute of limitations)
- Michel v. NYP Holdings, Inc., 816 F.3d 686 (11th Cir. 2016) (applies most significant relationship test in multistate defamation context)