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Up in Arms: Son of Former Albanian Prime Minister Claims Defamation in Arms-Dealing Controversy in Berisha v. Lawson

Niki Ozburn*

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In Berisha v. Lawson, the U.S. Court of Appeals for the Eleventh Circuit addressed a defamation suit brought by Shkelzen Berisha (“Berisha”), the son of Albania’s former Prime Minister, against a United States author, Guy Lawson (“Lawson”).  In analyzing the defamation claim, the court considered whether Berisha was a limited public figure in this circumstance, and, if so, whether he had to prove that Lawson acted with actual malice.  The court also expanded on the employee-equivalent theory as it relates to an independent contractor’s ability to claim attorney-client privilege for communications when the contractor is not a traditional employee. The importance of the Eleventh Circuit’s ruling in Berisha v. Lawson is two-fold: (1) it upholds the importance of the First Amendment within the judicial system, even when a public figure is an involved party; and (2) it brings further definition to the Supreme Court’s holding that the attorney-client privilege can be expanded to include non-traditional employees. 

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