Smartmatic Wins Defamation Ruling Against MyPillow’s Lindell (1)

MyPillow Inc. CEO Mike Lindell defamed the electronic voting machine company Smartmatic USA Corp. when he accused it of rigging the 2020 presidential election against Donald Trump , a Minnesota federal judge has ruled.

There is “simply no evidence” in the record presented to support a finding that Smartmatic designed its computer-based devices to manipulate ballots or that Smartmatic machines have been used to do so in other countries, Judge Jeffrey M. Bryan of the US District Court for District of Minnesota said on Sept. 26.

“To the contrary, the only evidence in the record concerning design shows that Smartmatic has not designed any of its election technology to manipulate ballots or steal elections,” Bryan said. The judge granted Smartmatic’s motion for partial summary judgment, and for injunctive relief under the Minnesota Deceptive Trade Practices Act, leaving aside for trial the issues of malice and damages. The company must file its proposed order for permanent injunctive relief by Dec. 1.

Smartmatic filed suit against Lindell and his company in January 2022, alleging the entrepreneur had made 51 false and defamatory statements for which he, and vicariously his company, should be held liable. The case is one of a several filed by Smartmatic and Dominion Voting Systems Inc. against Trump supporters who denied the accuracy of the 2020 election results.

L.A. Outcome

The controversy before Bryan arises out of results reported out of Los Angeles County, Calif., after the 2020 contest between Trump and then-victor Joe Biden. Of the more than 4.33 million votes cast, Biden won 71.04 percent, Trump just 26.87. Only 913,765 of those votes were cast in person, according to Bryan’s ruling. Los Angeles County was Smartmatic’s sole US customer for that election.

None of the Smartmatic computer-based ballot marking devices was used in the balloting were connected to the internet, Bryan said. None had wireless capability, and none of the company’s security measures “indicated the occurrence of any breach or tampering.”

And none of the devices were used to directly count or tabulate ballots, because the county used a different system, one provided to it by a nonparty.

Yet none of this stopped Lindell from claiming in four documentaries—the first of which was called Absolute Proof: Exposing Election Fraud and the Theft of America by Enemies Foreign and Domestic, that voting machines changed Trump votes to Biden votes. Lindell also appeared on at least 12 shows via radio, television and podcast to promote those documentaries, Bryan said.

The statements fall into one of the “well-established categories of defamation per se,” so the Court may “presume” that Lindell’s statement “tends to harm the plaintiff’s reputation,” the judge said.

Falsity Established

Rejecting Lindell’s argument that statements made claiming to be “absolute proof” or “scientific proof” are, instead, “non-factual opinions or conjecture,” Bryan said the content of Lindell’s 51 statements are sufficiently “factual in nature” to give rise to a defamation claim, often can be proven true or false, and are presented as “objectively verifiable or based on objectively verifiable facts.”

“Lindell was not purporting merely to express his opinion or surmise as to a subjective topic,” Bryan said. Rather, the premise of his documentaries and media appearances is that he, and his guests, “uncovered objectively true facts and wish to share those facts with the audience.”

All of his statements also explicitly attack the integrity of Smartmatic’s business “and/or directly or impliedly accuse Smartmatic of criminal misdeeds,” the judge said. “Defendants have not cited any evidence to the contrary.”

Smartmatic also established the falsity element of its defamation claim by conveying in each actionable statement at least one of three “overarching messages": that Smartmatic machines stole the 2020 Election or manipulated ballots to change its outcome; that its devices were connected to the internet and could be hacked; and that Smartmatic designed its machines to manipulate ballots and change election results, Bryan said.

Yet none of these messages can be true, he said. Still issues of fact remain as to whether the statements were made which knowledge they were false or with reckless disregard for their falsity, the court said.

Benesch, Friedlander, Coplan & Aronoff, Sidley Austin LLP, Thompson Hine LLP, and Jones Day represent Smartmatic. McSweeney, Cynkar and Kachouroff PLLC and Jennifer DeMaster of Grafton, Wisc. represent Lindell.

The case is Smartmatic USA Corp. v. Lindell, D. Minn., No. 0:22-cv-00098, 9/26/25.