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January 2011

Britney Spears’ Former Manager Not a Libel-Proof Plaintiff



Doctrine to Be Applied Sparingly if at All

A California appellate court undertook a lengthy analysis of the libel-proof plaintiff doctrine, concluding that it is not a bar to a libel suit brought by Sam Lufti, former manager of pop star Britney Spears.  Lufti v. Spears, 2010 Cal. App. Unpub. LEXIS 9310  (Nov 23. 2010) (Chavez, Boren, Ashmann-Gerst, JJ.).  The court found that the libel-proof plaintiff doctrine is to be sparingly applied – if used at all.