Olivet University v. Rouhandeh
8:24-cv-00771
M.D. Fla.Jan 13, 2025Background
- Olivet University sued journalist Alex Rouhandeh for defamation per se and tortious interference, relating to a series of Newsweek articles associating Olivet with criminal conduct.
- Olivet is an evangelical Christian university with campuses in several states; Rouhandeh lives and works in Florida.
- The disputed articles reference Olivet pleading guilty to money laundering, being under investigation for human/labor trafficking, and allegedly being associated with drug trafficking and other criminal investigations.
- Olivet previously sued over similar articles in New York, but Rouhandeh was dismissed from that case for lack of personal jurisdiction.
- Rouhandeh moved to dismiss the present suit, arguing California law (with a one-year statute of limitations) should apply, and raising several other defenses including lack of pre-suit notice, res judicata, and the single-action rule under Florida law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Choice of Law | Florida law applies | California law applies | Florida law applies, including its two-year statute of limitations |
| Preclusive Effect (Res Judicata) | Not barred, no privity | Prior NY judgment bars claim | Not barred; Rouhandeh not in privity and not bound by NY case |
| Sufficiency of Defamation Per Se Claim | Specific statements are defamatory | Claims not all specifically pled, not actionable | Only two statements survive: plea to money laundering and labor trafficking investigation |
| Tortious Interference & Single-Action Rule | Interference via defamatory articles | Insufficient specificity & single-action rule bars claim | Claim dismissed; no specific relationships or defamatory statement identified, notice insufficient |
Key Cases Cited
- Klaxon Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487 (forum state's choice-of-law rules govern in diversity)
- Bishop v. Fla. Specialty Paint Co., 389 So. 2d 999 (Fla. 1980) (Florida's most-significant-relationship test for torts)
- Jews For Jesus, Inc. v. Rapp, 997 So. 2d 1098 (Fla. 2008) (elements of defamation under Florida law)
- Kieffer v. Atheists of Fla., Inc., 269 So. 3d 656 (Fla. 2d DCA 2019) (substantial truth doctrine for defamation in Florida)
- Wolfson v. Kirk, 273 So. 2d 774 (Fla. 4th DCA 1973) (libel per se standard)