Rachel Maddow has been named in three major defamation lawsuits over her MSNBC broadcasts. Two were dismissed by federal courts on First Amendment grounds — one brought by One America News and one by former congressman Devin Nunes — and the third, brought by Georgia gynecologist Dr. Mahendra Amin over MSNBC’s “uterus collector” coverage, was settled by NBCUniversal in 2025 for a reported $30 million.
The OAN “Paid Russian Propaganda” Case
The first suit grew out of a July 22, 2019, segment on The Rachel Maddow Show. Discussing a Daily Beast article about OAN on-air reporter Kristian Rouz freelancing for the Russian state-financed outlet Sputnik, Maddow said OAN “really literally is paid Russian propaganda.”1Ninth Circuit Court of Appeals. Herring Networks, Inc. v. Maddow, No. 20-55579
OAN’s parent company, Herring Networks, sued Maddow, Comcast, NBCUniversal, and MSNBC in the U.S. District Court for the Southern District of California in September 2019, seeking $10 million. Herring argued the statement was false because OAN itself had never been paid by the Russian government.2First Amendment Watch. Judge Dismisses OAN’s $10 Million Libel Suit Against MSNBC’s Rachel Maddow
On May 22, 2020, U.S. District Judge Cynthia Bashant dismissed the case with prejudice under California’s anti-SLAPP statute. She concluded a reasonable viewer would not take Maddow’s remark as a factual claim. Maddow’s tone, including laughter and her description of the underlying story as a “sparkly story,” signaled commentary rather than a new accusation. The word “literally,” Bashant found, is commonly used as exaggeration and did not convert the line into a provable factual assertion.2First Amendment Watch. Judge Dismisses OAN’s $10 Million Libel Suit Against MSNBC’s Rachel Maddow
A unanimous Ninth Circuit panel affirmed on August 17, 2021. The court held the statement was “an obvious exaggeration, cushioned within an undisputed news story” and could not “reasonably be understood to imply an assertion of objective fact.” Because Maddow had laid out the underlying Daily Beast reporting about Rouz before offering her characterization, viewers would read the “paid Russian propaganda” line as hyperbolic opinion. The general tenor of the show, where audiences expect “subjective language” and “fiery rhetoric,” reinforced the conclusion.1Ninth Circuit Court of Appeals. Herring Networks, Inc. v. Maddow, No. 20-555793Courthouse News Service. Ninth Circuit Backs Dismissal of Defamation Suit Against Rachel Maddow
After the dismissal, Judge Bashant ordered Herring Networks to pay roughly $250,000 in attorneys’ fees and costs covering about 363 hours of attorney work. The Ninth Circuit also entitled the defendants to recover appellate fees.3Courthouse News Service. Ninth Circuit Backs Dismissal of Defamation Suit Against Rachel Maddow4Business Insider. OAN Ordered to Pay Maddow and MSNBC Legal Fees
The Devin Nunes Case
Devin Nunes, the former Republican congressman who became CEO of Trump Media & Technology Group, sued NBCUniversal over a March 18, 2021, segment. On air, Maddow said Nunes “refused to hand it over to the FBI, which is what you should do if you get something from somebody who is sanctioned by the U.S. as a Russian agent.” The “it” was a package Nunes had received from Andrii Derkach, a Ukrainian legislator the Treasury Department sanctioned in September 2020 for election interference.5Reuters. Trump Media CEO Nunes Loses Defamation Lawsuit Over Rachel Maddow Show
Nunes said the opposite was true: his staff had delivered the package, unopened, to the FBI the same day it arrived in December 2019, and he had notified then-Attorney General William Barr.6The Independent. Devin Nunes Trump Media Lawsuit Dismissed Rachel Maddow
In November 2022, U.S. District Judge P. Kevin Castel in the Southern District of New York allowed one narrow claim to proceed: the specific assertion that Nunes “refused” to turn over the package. Other challenged statements were dismissed as protected opinion, substantially true, or fair reports of official proceedings.7Reason. Devin Nunes Libel Claim Over Rachel Maddow Show Broadcast Can Proceed
On August 1, 2025, Judge Castel dismissed the remaining claim in a 24-page decision. Because Nunes is a public figure, he had to show by clear and convincing evidence that Maddow either knew her statement was false or acted with reckless disregard for the truth. Castel found Nunes had not met that bar. A July 2020 Politico article had reported the FBI received the package, but the court found no evidence Maddow was aware of it. The judge also rejected the argument that Maddow’s political opposition to Nunes amounted to proof of malice, writing there was no evidence the “defendant’s admitted political bias caused defendant to act with a reckless disregard of the truth.”5Reuters. Trump Media CEO Nunes Loses Defamation Lawsuit Over Rachel Maddow Show
The Dr. Mahendra Amin “Uterus Collector” Case
The third suit followed MSNBC’s 2020 coverage of a whistleblower complaint by Dawn Wooten, a nurse at the Irwin County Detention Center in Georgia, who alleged a gynecologist treating ICE detainees was performing unnecessary procedures including mass hysterectomies. Maddow, Nicolle Wallace, and Chris Hayes aired segments characterizing the doctor, Mahendra Amin, as the “uterus collector” and reporting on allegations of mass hysterectomies at the facility.8NPR. NBC Settles Lawsuit ICE Doctor MSNBC Maddow Georgia Detainee
Dr. Amin sued NBCUniversal, MSNBC, Maddow, Wallace, and Hayes in the Southern District of Georgia in September 2021, seeking $10 million in compensatory damages and $20 million in punitive damages. His attorneys said he received death and bomb threats, lost patients, lost his medical service contract with the ICE facility, and withdrew from community life.8NPR. NBC Settles Lawsuit ICE Doctor MSNBC Maddow Georgia Detainee
In June 2024, U.S. District Judge Lisa Godbey Wood issued a pretrial ruling that reshaped the case. She wrote that “the undisputed evidence establishes that multiple NBC statements are false.” The court determined Dr. Amin had performed only two hysterectomies on detainees at the facility, that there were no mass hysterectomies, and that the “uterus collector” label was false. Judge Wood also rejected NBC’s argument that it was protected because its journalists were relaying claims made by the whistleblower, finding that on-screen headlines such as “COMPLAINT: MASS HYSTERECTOMIES PERFORMED ON WOMEN AT ICE FACILITY” actively promoted the false narrative rather than neutrally reporting it.8NPR. NBC Settles Lawsuit ICE Doctor MSNBC Maddow Georgia Detainee9Reason. Judge Concludes NBC’s Allegations of Mass Hysterectomies by Doctor at ICE Facility Were False
On actual malice, the court found Dr. Amin had presented enough evidence to let a jury decide. Internal NBC communications uncovered in discovery showed reporters and hosts had early reservations. NBC’s internal standards deputy documented significant doubts about Wooten’s credibility, noting she had “no direct knowledge” and “no evidence to back up her claims.” Reporter Julia Ainsley asked a colleague by text, “Just two hysterectomies?” Chris Hayes acknowledged he had initially “discounted the whole thing.”9Reason. Judge Concludes NBC’s Allegations of Mass Hysterectomies by Doctor at ICE Facility Were False Maddow was deposed and, according to reporting on the discovery record, had been personally involved in editorial vetting and off-camera conversations around the segments “to an extent that can be unusual for on-camera hosts.”10Washington Free Beacon. NBC Settles Defamation Lawsuit With Georgia Doctor Whom Rachel Maddow Dubbed the Uterus Collector
With a jury trial scheduled for April 22, 2025, NBCUniversal settled. The parties filed a joint notice of settlement in February 2025, and Dr. Amin formally dismissed the case on April 4, 2025. Adweek reported the settlement was for $30 million, the full amount Dr. Amin had sought. NBC did not publicly comment on the figure, and some outlets described the terms as undisclosed.11Adweek. NBC News Mahendra Amin Settlement Defamation Case8NPR. NBC Settles Lawsuit ICE Doctor MSNBC Maddow Georgia Detainee
Why the Three Cases Ended So Differently
Each suit turned on a different piece of defamation doctrine.
The OAN case turned on the opinion-versus-fact line. Courts never had to decide whether the “paid Russian propaganda” characterization was accurate, because they concluded no reasonable viewer would hear it as a factual claim in the first place. Hyperbole layered on top of disclosed facts, delivered in Maddow’s recognizable commentary register, was protected speech.
The Nunes case turned on actual malice. Judge Castel treated the statement that Nunes “refused” to hand the package over as the kind of concrete, falsifiable claim that can support a defamation suit, and let it survive the first round of dismissal. What sank the case at the second round was the absence of evidence that Maddow knew the claim was wrong or recklessly ignored contrary information. Political bias alone, Castel wrote, is not proof of malice.
The Amin case was different in kind. A federal judge found the key statements were provably false, that NBC’s own reporters had voiced doubts in internal communications before airing them, and that a jury could reasonably find the network acted with actual malice. With those findings on the record and trial weeks away, NBCUniversal settled rather than put the question to a jury.