On July 10, 2019, the United States District Court for the Eastern District of Pennsylvania dismissed with prejudice a defamation and false light lawsuit filed by a dancer at a New Jersey Strip club against the New York Daily News, holding that the plaintiff had failed to plead actual malice with respect to her claims.
The case stemmed from a December 2017 Daily News article about the government-ordered closing of the strip club Satin Dolls, best known as a frequent filming location for a popular television series. The article noted that New Jersey state authorities had ordered the shutdown of Satin Dolls after accusing the club of engaging in illegal activity, such as alleged prostitution, lewd activity, racketeering, and extortion-related charges. The article was accompanied by a photograph of two Satin Dolls employees posing with merchandise related to the television series. One of the photographed employees, Diane LoMoro, subsequently sued the Daily News for defamation, claiming that the article falsely linked her to alleged criminal conduct; that the paper allegedly doctored the photo to make Ms. LoMoro appear “fatter, larger, uglier, blotchier, discolored, disproportionate, and grotesque”; and that the Daily News allegedly invaded Ms. LoMoro’s privacy by portraying her in a false light.