Pujols v. Pujols Family Foundation, 4:16-cv-01644

Background

Plaintiff Wilfrido Pujols (former pro baseball player) sued Albert Pujols, Deidre Pujols, and the Pujols Family Foundation for defamation and Albert Pujols for intentional infliction of emotional distress (IIED), seeking at least $7.5M.
Central documents: a December 7, 2007 email from Deidre (response to the victim’s mother) and a November 4, 2014 Facebook reposting of that email by the victim’s mother; plaintiff alleges he first learned of the 2007 email in 2014.
The 2007 email included subjective language (e.g., “something so heinous,” “these two young men have ruined many lives,” assurances the Pujolses would not support the young men).
Plaintiff also alleges that in July 2016 Deidre and Albert told Kristen Peter that plaintiff had felonies for manslaughter and had served two years in jail.
For IIED, plaintiff alleges Albert made “mafia‑style” threatening phone calls in July 2016 and that a purported private investigator later contacted his father.
Court reviewed motion to dismiss (Rule 12(b)(6)) applying Missouri law and pro se pleading standards.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are the statements in the 2007 email actionable defamation?	The email implies plaintiff committed criminal conduct and thus is defamatory.	The email is opinion/rhetorical and protected by the First Amendment; not provable false statements of fact.	Dismissed — statements are non‑actionable opinion protected by the First Amendment.
Is defendant liable for republication (2014 Facebook post) and is the claim timely?	Plaintiff alleges the email was republished in 2014; he first learned then, so claim timely.	(Argued) republication and statute of limitations bar or defeat liability.	Court did not reach statute‑of‑limitations or republication issues because 2007 email is nonactionable opinion.
Are the alleged statements to Kristen Peter sufficiently pleaded and actionable?	Plaintiff says Deidre/Albert told Peter plaintiff had manslaughter felonies and served two years; this imputes crime.	Defendants argue allegations lack specificity and context; damages not pled.	Partially held: statements pleaded sufficiently and are defamatory (imputing crime), but claim dismissed for failure to plead actual damages causally linked to those statements.
Does plaintiff state a IIED claim against Albert Pujols?	Threatening phone calls and contacts caused severe emotional distress.	The alleged phone calls and PI contact are not extreme/outrageous enough as a matter of law.	Dismissed — conduct alleged is not sufficiently extreme and outrageous under Missouri law.

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleading)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974) (states may limit liability for expressions of opinion)
New York Times Co. v. Sullivan, 376 U.S. 254 (1964) (actual malice standard for public‑figure defamation)
Milkovich v. Lorain Journal Co., 497 U.S. 1 (1990) (opinions that imply provable false facts can be actionable)
Smith v. Humane Soc’y of United States, 519 S.W.3d 789 (Mo. 2017) (Missouri recognizes absolute privilege for expressions of opinion)
Nazeri v. Missouri Valley College, 860 S.W.2d 303 (Mo. 1993) (Missouri requires proof of actual damages in defamation actions)