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Libel

No Libel in "Murder for Hire Conspiracy Case Results in Conviction" Headline,

even though (as the full article explained) the conviction was for attempt to commit stalking, not for conspiracy to commit murder.

Eugene Volokh | 4.23.2026 8:01 AM

From Magistrate Judge Anthony Porcelli (M.D. Fla.) in Ligeri v. Arizona Daily Independent, LLC, decided March 10 but just posted to Westlaw:

Plaintiff holds himself out as an established entrepreneur in the e-commerce space. He is the Founder and CEO of Kangaroo Manufacturing & Ranked 1Pro Events. Through these businesses, Plaintiff generated "record-breaking sales on Amazon," fostered a reputation in the online retail sales community, and has shared his expertise on manufacturing, importing, and ranking products on Amazon at various conferences.

At some point, Plaintiff's business relationship with two associates, Joshua Dean Tischer and John Andrew Burns, soured due to issues with repaying debts. Out of fear for losing his business, Plaintiff made numerous threats of death and bodily injury to Burns and offered to pay someone to harm Tischer and Burns because Plaintiff believed they wronged him. Investigators gathered recorded calls, text messages, and witness statements in furtherance of "a possible murder for hire case."

Ultimately, in April 2021, the Mesa Police Department arrested and charged Plaintiff with Aggravated Assault, Stalking – Fear of Death, and Stalking – Fear of Physical Injury. Plaintiff was never charged with murder or conspiracy to commit murder or murder for hire. On March 24, 2022, Plaintiff pleaded guilty to Attempt to Commit Stalking.

On March 28, 2022, Defendant published a news report on Plaintiff's case titled Murder For Hire Conspiracy Case Results In Conviction Of Former Online Retail Star (the "Article"). [Note that the article title actually appears to be "Murder For Hire Conspiracy Case Results In Conviction Of Former Amazon........

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