Coach who bullied Miami Dolphins player loses defamation suit

By Dee Thompson | Feb 6, 2018

The 11th Circuit Court of Appeals has ruled that Miami Dolphins offensive line coach James Turner, who was fired in 2014 for bullying a player, has no case against the law firm that investigated the bullying incident.


ATLANTA -- The 11th Circuit Court of Appeals has ruled that Miami Dolphins offensive line coach James Turner, who was fired in 2014 for bullying a player, has no case against the law firm that investigated the bullying incident. 

Offensive lineman Jonathan Martin left the Dolphins in midseason in 2013 and checked himself into a mental health facility. He had been with the Dolphins for two years. He later said he had quit the team because of persistent taunting from his fellow players and oTurner. 

The National Football League hired the New York law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP. Theodore Wells, a partner in the firm, investigated allegations of bullying within the Dolphins organization. The Dolphins fired Turner, in February 2014, after receiving the report from the law firm.

Paul, Weiss published a 144-page report after investigating for several months. It concluded Martin’s decision to leave the team came after bullying by other Dolphins players. The report also included several references to Turner. Turner’s unprofessional conduct played a role in Martin’s struggles, the report determined.

After his employment was terminated, Turner filed suit in federal court against the law firm and Wells, alleging defamation claims under Florida law. The district court dismissed Turner’s complaint with prejudice for failure to state a claim, and Turner appealed that ruling.

The Dolphins drafted Martin in the second round of the 2012 NFL draft out of Stanford and started him in every game during the 2012 season. In the 2013 season, Martin was a starting offensive left tackle on the Dolphins offensive line.  

The court’s order notes, “As recounted in greater detail below, Martin’s fellow offensive linemen subjected him to extensive taunting during his first year, referring to him with crude and often racially insensitive terms. Martin’s peers also disparaged his sister and mother with sexually explicit remarks.” 

Martin said the harassment continued and worsened during the 2013 season. On Oct. 28, 2013, Martin left a team dinner at the Dolphins practice facility. He checked himself into a hospital seeking psychiatric treatment that day.

The firm of Paul, Weiss, Rifkind, Wharton & Garrison was hired to investigate. Theodore Wells lead the investigation, in which attorneys and paralegals interviewed current and former Dolphins players, the coaching staff and front office personnel, Martin’s parents and agent. Wells' group also reviewed emails and text messages between Martin and his teammates and coaches.  Altogether they interviewed more than a 100 witnesses, including Turner. 

The report released Feb. 14, 2014, noted Dolphins coaches and players created a culture that enabled the bullying by discouraging players from “snitching” on other players. 

According to the order, “It concluded that ‘the treatment of Martin and others in the Miami Dolphins organization at times was offensive and unacceptable in any environment, including the world professional football players inhabit.’ Five days after Paul, Weiss released its report, the Dolphins fired Turner.”

In September 2015, Turner filed his complaint against the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP and Theodore Wells, alleging the report defamed him. 

In July 2016, the district court entered an order granting the defendants’ motion to dismiss. Turner appealed. 

The 11th Circuit Court of Appeals agreed with the lower court and concluded its decision by saying: “After careful review, and with the benefit of oral argument, we affirm the district court’s dismissal. We conclude that none of the challenged statements contained in the report are actionable for defamation. Further, no alleged omission or juxtaposition of facts in the report states a claim for defamation by implication. We also hold that Turner is a public figure who has failed to adequately plead that the defendants acted with malice in drafting and publishing the Report.”

The case was before Judges Joel Dubina, Frank M. Hull, Jane Restani. 

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