Muzikowski v. Paramount Pictures Corporatio

Facts

Robert Muzikowski (P), a securities broker, was active in founding and coaching inner-city Little League Baseball programs in very poor neighborhoods. P's charity work was featured nationally on programs such as ABC’s Nightline. In 1991, author Daniel Coyle volunteered to coach with the NNLL. The next season, 1992, Coyle took a leave of absence from his job as an editor at Outside magazine so that he could continue his work as an assistant coach of one of Near North’s teams and at the same time write a book about the experience. The end result was Hardball: A Season in the Projects, which G.P. Putnam’s Sons published in 1994. The book focuses primarily on the children Coyle coached, although it also devotes some attention to the coaches. Prominent among those coaches is P. Paramount (D) acquired the motion picture rights and seven years later produced the movie Hardball, which tells the story of a coach named Conor O’Neill. No character in the movie is named Robert or Muzikowski, and there are no references to Little League Baseball. The credits of Hardball state, “While this motion picture is in part inspired by actual events, persons and organizations, this is a fictitious story and no actual persons, events or organizations have been portrayed.” O’Neill experiences almost exactly the same things as the real P. The only differences were that O’Neill never breaks his drinking habit, O’Neill, unlike P, scalps tickets and gambles. O'Neill commits such crimes as battery, theft, criminal destruction of property, disorderly conduct, and drinking on the public way. From a professional standpoint, O’Neill falsely represents himself as a broker, even though he has no license. O’Neill uses his father’s death to deceive others into giving him money, and he is portrayed as having no interest in children or their well-being in contrast to P’s deep commitment to young people. P became involved in Little League solely out of that genuine concern for children, while the O’Neill character does so only to pay off a gambling debt. When D announced to the public that it was going to make the movie Hardball, P began getting telephone calls from all over the country from friends and acquaintances telling him that D was about to make a movie about him. D made it clear that Hardball was to be based on Coyle’s book and that it was about an inner-city baseball team based on a team located in the Cabrini-Green housing projects. An article prepared by the Associated Press said that Keanu Reeves “plays Bob Muzikowski, a former addict turned devout Christian, who coaches a Little League baseball team.” Most of the other advance publicity also emphasized the fact that the movie was based on the true account found in Coyle’s book. P sued alleging libel and various other claims. P sought a preliminary injunction to prevent Hardball’s release. P then voluntarily dismissed his California action and filed this suit in the Northern District of Illinois, asserting claims of defamation and false light invasion of privacy under Illinois law. P moved for a temporary restraining order to prevent release of the film, which the district court denied. The district court granted D’s motion to dismiss based on FED. R. CIV. P. 12(b)(6).

Issues

Rule of Law

Holding and Decision

Legal Analysis

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