Second Circuit Affirms Judge Oetken's Decision Dismissing Art Authenticator's Defamation Claims Against the New Yorker

The Second Circuit today affirmed Judge's Oetken's decision from August 2013 dismissing defamation claims against the New Yorker stemming from a 2010 profile of Peter Paul Biro, a specialist in art authentication through fingerprint analysis who was featured in the documentary Who the #$&% is Jackson Pollock?.  The Second Circuit found that Rule 8 requires a "limited-purpose public figure" to plausibly plead that defendants acted with actual malice, which the plaintiff in this case had failed to do. Our previous coverage of the case is here. H/T How Appealing