Judge Rules Patrick Byrne Not Liable in Defamation Case
A federal judge cleared the producer of a 2020 film regarding election results of defamation claims.
Updated on Oct. 28, 2026 in Elections
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U.S. District Judge Tom Barber ruled that Patrick Byrne is not liable in a defamation lawsuit involving claims made in his 2020 film, The Deep Rig. The court determined the plaintiff failed to meet the actual malice standard required by Colorado law.
Why it matters
The ruling highlights the high legal threshold for defamation claims regarding matters of public concern. It underscores the necessity of proving that a defendant subjectively disbelieved their own claims to hold them accountable in court.
Colorado law requires plaintiffs to provide clear and convincing evidence of actual malice in defamation cases. The court ruled that the plaintiff failed to show that Patrick Byrne subjectively believed the allegations in his film were false.
The players
Patrick Byrne
He is a former CEO and the producer of the film titled The Deep Rig.
Eric Coomer
He is a former Dominion Voting Systems executive who initiated the defamation litigation.
Tom Barber
He is the U.S. District Judge presiding over the defamation case in Florida.
Joseph Oltmann
He is an individual who made allegations in the film about election manipulation.
Dominion Voting Systems
This is a voting technology company that has secured over $1.8 billion in various legal settlements.
The details
Eric Coomer filed the 2022 lawsuit after Joseph Oltmann alleged in the film that Coomer manipulated 2020 election results to oppose Donald Trump. Judge Tom Barber found insufficient evidence that Byrne acted with actual malice when producing the film.
Timeline
2020: The Deep Rig film was released alleging an election conspiracy.
2022: Eric Coomer filed the defamation lawsuit against eight entities.
October 2026: Judge Tom Barber issued the ruling clearing Patrick Byrne.
Political Context
This case tests the limits of the actual malice standard, a cornerstone of U.S. defamation law that protects speakers from liability unless they acted with reckless disregard for the truth. Critics argue this high bar makes it difficult for individuals to defend their reputations against widespread misinformation.
The legal outcome reinforces the strict evidentiary requirements citizens must meet when pursuing defamation cases regarding public discourse. It signals that proving malicious intent remains a primary hurdle for plaintiffs challenging claims in political films.
The takeaway
This decision illustrates why establishing subjective intent is critical in high-stakes defamation litigation. Readers should recognize that the court requires more than just evidence of a false claim to establish legal accountability for public statements.
Further reading
For more information on national political proceedings, visit United States Elections.
Source note: This article includes information reported by CyberScoop.
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