Lenny Dykstra’s Loss Portends the Future of Defamation Cases

Former New York Mets and Philadelphia Phillies outfielder Lenny Dykstra’s own bad reputation led a court to toss his defamation case against former teammate Ron Darling, and law professors say the ruling has the potential to expand the infrequently used “libel-proof plaintiff” doctrine in other cases.

The doctrine bars relief in defamation actions if a plaintiff has a reputation that is so badly tarnished that he or she can’t be further injured by allegedly false statements. Judge Robert D. Kalish of the New York Supreme Court, New York County found that Darling put forth enough evidence to invoke the doctrine, ...