Christopher Chandler v. Donald Berlin — D.C. Cir. (Nov 2, 2026)
The D.C. Circuit reviews a defamation verdict over a confidential report. Businessman Christopher Chandler sued a private investigator and his company over a 2003 report accusing Chandler of money laundering. Chandler denied the allegations, and said he first saw the report when British journalists showed it to him in 2018. The report had originally gone to a client; years later, its contents appeared in the British press. An earlier appeal allowed the claim over the investigator's original publication to proceed, but barred damages for the later British-media republication. A jury later awarded Chandler about eight million dollars. In defamation law, publication means communicating a statement to someone else, not necessarily printing it in a newspaper. The damages dispute concerns which harm came from the original circulation rather than the excluded media coverage. You'll also hear about presumed damages: compensation for reputational injury without proving a specific financial loss. The discovery rule asks when Chandler knew, or reasonably should have known, of injury from the investigator's wrongdoing. Jim Campbell will argue for the investigator and his company; Daniel Watkins will defend Chandler's verdict.
Christopher Chandler v. Donald Berlin (No. 26-7008) — U.S. Court of Appeals for the D.C. Circuit, argued November 2, 2026.
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