Cameo Clips

The U.S. District Court for the Southern District of New York decided that a legend at the end of the movie 'American Gangster' ' stating that events depicted 'led to the conviction of three quarters of New York City's Drug Enforcement Agency' ' was non-defamatory because it wasn't 'of and concerning' any particular individual. Diaz v. NBC Universal Inc., 08 Civ. 401(CM). 'American Gangster,' starring Denzel Washington and Russell Crowe, was based on the real-life story of one-time heroin dealer Frank Lucas, who cooperated with law-enforcement officials. The plaintiffs, who had worked for the DEA, filed suit on behalf of 'approximately 400 present and former Special Agents of the New York office of the United States Drug Enforcement Administration.' The statement in the movie about the convictions wasn't true, but the district court dismissed the complaint under the 'group libel doctrine.' The court noted: 'When a reference is made to a large group of people, no individual within that group can fairly say that the statement is about him, nor can the 'group' as a whole state a claim for defamation.'

In the Southern District of New York, courts apply the group-libel doctrine to suits brought by groups exceeding 60 members. But the Diaz plaintiffs argued that 'each of them can be identified by an average viewer because the film depicts as corrupt virtually the entire New York City narcotics law enforcement community.' The district court emphasized, however, that 'the legend did not cast a cloud over the entire (non-existent) 'New York City DEA'; it said that a fraction (albeit a substantial fraction) of the members of that group were convicted.'