A long-running legal battle between The Satanic Temple and Newsweek has finally wrapped up—with the firm’s client, Newsweek, emerging on top. A court ruled that The Satanic Temple couldn’t prove the magazine acted with “actual malice,” which is the high legal standard that has to be met in defamation cases involving public issues, thanks to New York’s anti-SLAPP statute.
The Satanic Temple had sued Newsweek and freelance journalist Julia Duin over an article that reported on a lawsuit involving the Temple and some of its former members. Plaintiff claimed the article contained 22 defamatory statements. But the court threw out 21 of them early on and dismissed Duin from the case on personal jurisdiction grounds. That left just one statement in question—a quote from a former member who said he left the Temple after hearing about reports of sexual abuse being covered up.
After discovery, both sides moved for summary judgment. Newsweek argued there was no proof the quote was false or that it was published with “actual malice.” Plaintiff argued there was sufficient evidence to show the quote was misleading and that Newsweek was at fault—even if the court decided the stricter “actual malice” standard applied.
On the question of whether the quote was false, the judge said it was a close call. The quote could be interpreted in a few different ways—some harmless, some possibly defamatory. So, the court decided that part of the case couldn’t be resolved without a jury.
But when it came to proving “actual malice,” The Satanic Temple hit a wall. Under New York law, when a plaintiff sues over public interest reporting, it has to show the statements at issue were published with either knowledge that they were false or with serious doubts about their truth. That’s a tough bar to clear—and the court said the evidence just didn’t cut it.
The court noted that Newsweek’s editor trusted Duin and had no reason to doubt her work. Duin said she believed the quote was accurate and was substantiated with additional interviews and research. The Temple argued Duin should have been more skeptical because the source was a former member with a grudge. But the court held there was no proof Duin seriously doubted the truth of the statement or ignored red flags about it.
The Temple also argued the article was biased against it—but again, the judge wasn’t convinced. In the end, the court ruled there just wasn’t enough evidence to show Newsweek acted with actual malice, and that no reasonable jury could rule in the Temple’s favor. So, the case was dismissed.