This post is about the recently filed defamation case brought by a 19-year old American chess player named Hans Moke Niemann against world champion Magnus Carlson and several other defendants alleging that Niemann was defamed by allegations that he has cheated at chess tournaments.  

As an aside, this is at least the second recent lawsuit to come out of the world of chess.  In 2021, a chess player from (the country of) Georgia named Nona Gaprindashvili, at one time the women's world champion, sued Netflix claiming that she had been defamed by the television series "Queen's Gambit" because the show included a line stating that Ms. Gaprindashvili had never faced men when she had, in fact, played several male champions. After Netflix failed to have the claim thrown out via an early motion to dismiss, the parties settled the case.  

Turning to the current suit, the world of chess was jolted recently when World Champion Magnus Carlson accused Niemann, a comparatively low-ranked opponent, of cheating at recent tournaments.   On October 20, 2022, Niemann filed a 44-page lawsuit in federal court in Missouri. The defendants include Carlson, the online chess company founded by Carlson called Play Magnus Group, the online chess brand (which recently purchased Play Magnus Group), Danny Rensch who is an executive of and an influential chess blogger named Hikaru Nakamura.  The complaint, which can be viewed here, includes claims for slander (i.e., verbal defamation) and libel (i.e., written defamation) along with claims for tortious interference with contract and business relations, "civil conspiracy" and violations of the Sherman Antitrust Act (arising from the contention that the defendants acted in concert in refusing to deal with Niemann and blacklisting him from various events).  

In his complaint, Niemann accuses Carlson and the other individual defendants of falsely implying or stating that Niemann had cheated.  He also alleges that defamed him in a 72-page report following its investigation into allegations concerning Niemann.  While that report did not identify any definitive evidence of cheating, it concluded that Niemann's results are "statistically extraordinary" and that “there are many remarkable signals and unusual patterns in Hans’ path as a player.”   

Niemann alleges that the actions of the defendants have effectively ruined his chess career and his life.  He claims he has been barred from many chess tournaments and that the actions of the defendants have deprived him of potential revenue from teaching and from endorsements.  All told, Niemann seeks money damages in excess of $100 million

It is pretty difficult to establish that someone is cheating during a live chess tournament. Most of the time the accusations center around a player allegedly having access to information from a so-called chess engine -- a computer program designed to analyze the relative strength of various moves -- and then somehow receiving information via an electronic or other signal.   Niemann has acknowledged that he cheated in at least two instances much earlier in his chess career.  

This case may be an interesting one to watch.  Assuming that the defendants have difficulty producing definitive proof to support the allegations of cheating, they are likely to argue that the statements at issue were, at most, non-actionable opinions based upon disclosed facts. They also likely will content that even if wrong, any statements were not made with the requisite knowledge of falsity or disregard for the truth that is required to meet the "actual malice" standard for this type of claim.