Brandel Chamblee and the Golf Channel Are Accused of Defamation in Patrick Reed’s Lawsuit

The golf world is once again experiencing drama as Patrick Reed recently filed a defamation suit against the Golf Channel and Brandel Chamblee, seeking over $750 million in damages.¹ Reed claims he has been a target of criticism since he was twenty-three years old, with allegations of cheating following him throughout his career due to Chamblee’s commentary.² According to Reed, the Golf Channel, and Chamblee have conspired against him to destroy his reputation, discredit his accomplishments, and create a hostile work environment.³

The recent criticism from the Golf Channel and Chamblee has stemmed from Reed’s switch to LIV Golf.⁴ Reed claims the defamatory remarks aimed to eliminate LIV Golf from the competition, tarnishing his reputation among fans to destroy one of LIV’s top players.⁵ According to Reed, the comments angered fans, caused substantial emotional and financial damage, and impaired his standing in the golf community.⁶ PGA tour fans, for example, since Chamblee’s remarks have shouted comments at Reed, telling him, “You Suck!” and “No one likes you!”⁷ These defamatory remarks, made with a “reckless regard for the truth,” Reed claims, have caused his livelihood to suffer by hurting his reputation among fans and making him lose out on multi-million-dollar sponsorship deals.⁸

Unfortunately for Reed, his defamation lawsuit was dismissed by a federal judge in Florida for failing to provide defendants with notice of the grounds of each claim.⁹ Reed’s complaint alleges 120 factual allegations, incorporating each of these facts into each count.¹⁰ The complaint attempts to allege various civil conspiracy and defamation violations against each defendant; however, each of these causes of action requires vastly different sets of factual allegations.¹¹

Reed’s complaint alleges that Chamblee and the Golf Channel misrepresented information to mislead the public.¹² However, a true statement cannot be deemed defamatory.¹³ To constitute defamation, a false statement must be presented as truth to a third party.¹⁴ Reed will have to show the statement caused harm, and since he is a public figure, that the statement was published with malice, fault, or negligence.¹⁵ Given how essential falsity is to a defamation action, only facts that can be proven false may be brought.¹⁶  Pure opinions cannot constitute defamation.¹⁷ Through prior decisions, the courts have held that an opinion that is neither true nor false cannot be declared defamation since it does not meet the falsehood requirement.¹⁸ Considering that exaggeration and non-literal commentary are now used widely in social interactions and commentary, the first amendment protects this dubbing it ‘rhetorical hyperbole.’¹⁹ While Chamblee’s criticisms have been harsh, including comments about Reed “destroying the game of golf and its reputation” and calling him “one of the most greedy, self-serving, self-interested players in the world of golf today” these statements, while cruel, are opinions, and do not appear to fit the definition of defamation.²⁰

Reed has recently refiled an amended complaint, increasing the damage he is seeking to $820 million due to the loss of multi-million-dollar sponsorship deals from major golf brands such as Nike, Titleist, and Callaway.²¹ In his amended complaint, Reed alleges that golf media has defamed him and other LIV Golf players and have hired people to defame them in the media to ruin their reputation and harm the progress of LIV Golf.²²

That’s not all. Reed recently threatened CNN, Bob Costas, and Bloomberg with a lawsuit seeking over 450 million dollars in damages for posting a video segment criticizing LIV Golf.²³ The segment titled ‘The Court Fight Between PGA Tour and LIV Golf Escalates as the Saudi-Backed LIV Tries to Avoid Handing Over Information’ was deemed highly defamatory by Reed.²⁴ Though the commentators did not mention Reed personally, they asserted that LIV Golfers were “tak[ing] blood money from the Saudi Public Investment Fund, in the wake of the 9/11 tragedy twenty-two years ago.”²⁵ Reed alleges that the segment was designed to ridicule LIV Golf players and incite hatred and violence against them.²⁶ He is calling for the segment to be retracted and an apology issued.²⁷ However, CNN is refusing, declaring that any lawsuit Reed might try to bring against them would be frivolous, only serving to intimidate journalists from covering important news about the Saudi-backed LIV Golf tournament.²⁸

It is undeniable that golf media’s statements about Patrick Reed and LIV Golf have been hurtful and cruel and do not benefit his reputation. However, it remains to be seen whether they constitute defamation.

Alexandria Ciardullo is a Second Year Law Student at the Benjamin N. Cardozo School of Law and a Staff Editor at the Cardozo Arts & Entertainment Law Journal. Alexandria is interested in corporate law, antitrust and international law.

1. Jay Rigdon, Patrick Reed’s $750 Million Lawsuit Saga Somehow Got Even Weirder, Awful Announcing (Sep. 29, 2022) https://awfulannouncing.com/golf/patrick-reeds-750-million-lawsuit-saga-somehow-got-even-weirder.html. (Brandel Chamblee is a former professional golfer and current commentator.)
2. Kyle Porter, Former Masters Champion Patrick Reed Seeks $750 Million in Defamation Lawsuit Over On-Air Criticism, CBS Golf (Aug. 16, 2022) https://www.cbssports.com/golf/news/former-masters-champion-patrick-reed-seeks-750-million-in-defamation-lawsuit-over-on-air-criticism/; John Hawkins, To Win a Defamation of Character Suit, Patrick Reed Would Need Character to Begin With, Sports Illustrated (Aug. 17, 2022) https://www.si.com/golf/news/to-win-a-defamation-of-character-suit-patrick-reed-would-need-character-to-begin-with.
3. Mark Schlabach, Judge Dismisses Patrick Reed’s Defamation Lawsuit vs. Golf Channel, ABC News (Nov. 19, 2022)https://abcnews.go.com/Sports/judge-dismisses-patrick-reeds-defamation-lawsuit-golf-channel/story?id=93608864.
4. Jeff Ritter, Top Golf Newsmakers of 2022: LIV Golf and Lawsuits for Patrick Reed, Sports Illustrated (Dec. 22, 2022) https://www.si.com/golf/news/top-golf-newsmakers-of-2022-patrick-reed.
5. Mike McDaniel, Patrick Reed’s Defamation Lawsuit Against Chamblee, Others Dismissed, Sports Illustrated (Nov. 19, 2022) https://www.si.com/golf/news/patrick-reeds-defamation-lawsuit-against-chamblee-others-dismissed; Patrick Reed’s Libel Case is a House Built on Sand, Lying Four (Aug. 17, 2022) https://www.lyingfour.com/conversations-blog/2022/8/17/patrick-reeds-libel-case-is-a-house-built-on-sand.
6. McDaniel, supra note 5 ; Complaint, Patrick Nathaniel Reed vs. Brandel Chamblee & Golf Channel , No. 3:22-cv-1059-TJC-PBD U.S. Dist. LEXIS 190259 (M.D. Fla. 2022).
7. Patrick Reed’s Libel Case is a House Built on Sand, Lying Four (Aug. 17, 2022) https://www.lyingfour.com/conversations-blog/2022/8/17/patrick-reeds-libel-case-is-a-house-built-on-sand.
8. Porter, supra note 2.
9. Schlabach, supra note 3.
10. McDaniel, supra note 5.
11. Id.
12. Patrick Reed’s Libel Case is a House Built on Sand, Lying Four (Aug. 17, 2022) https://www.lyingfour.com/conversations-blog/2022/8/17/patrick-reeds-libel-case-is-a-house-built-on-sand.
13. Id.
14. Christy Bieber, Defamation Lawsuit Guide 2023, Forbes Advisor (Oct. 17, 2022) https://www.forbes.com/advisor/legal/personal-injury/defamation-lawsuit-guide/
15. Online Defamation Law, EFF https://www.eff.org/issues/bloggers/legal/liability/defamation
16. Milkovich v. Lorain Journal Co., 497 U.S. 1 (1990).
17. Id.
18. Dickinson v. Cosby, 17 Cal. App. 5th 655 (2017).
19. Patrick Reed’s Libel Case is a House Built on Sand, Lying Four (Aug. 17, 2022) https://www.lyingfour.com/conversations-blog/2022/8/17/patrick-reeds-libel-case-is-a-house-built-on-sand.
20. Complaint, Patrick Nathaniel Reed vs. Brandel Chamblee & Golf Channel, No. 3:22-cv-1059-TJC-PBD U.S. Dist. LEXIS 190259 (M.D. Fla. 2022).
21. Ben Smith, Patrick Reed Trolled with Star Wars References in Court Documents, Golf Magic (Jan. 15, 2023) https://www.golfmagic.com/liv-golf/patrick-reed-trolled-star-wars-references-court-documents.
22. Matt Cradock, Patrick Reed Files $820 Million Amended Complaint Against Brandel Chamblee Golf Monthly (Dec. 18, 2022) https://www.golfmonthly.com/news/patrick-reed-files-dollar820-million-amended-complaint-against-brandel-chamblee.
23. A.J. Perez, Patrick Reed’s Lawyer Threatens Bob Costas, CNN with $450M Lawsuit, Front Office Sports (Jan. 18, 2023) https://frontofficesports.com/patrick-reeds-lawyer-threatens-bob-costas-cnn-with-450m-lawsuit/.
24. Paulina Dedaj, LIV Golf’s Patrick Reed Demands Public Apology from CNN’S Jake Tapper and Bob Costas, Threatens $450M Lawsuit, Fox News (Jan. 18, 2023) https://www.foxnews.com/sports/liv-golfs-patrick-reed-demands-public-apology-cnns-jake-tapper-bob-costas-threatens-450m-lawsuit.
25. Id.
26. Id.
27. Id.
28. Perez, supra note 23.