Florida Court Says That Docuseries Can Be Considered Multiple Publications In A Defamation Action

The makers of a docuseries about a man who was allegedly scammed by his wife are appealing a Florida appellate court’s decision.

Paul T. Goodman is a drama/docuseries about a real man, Paul Finkelman, who claims his wife scammed him and led a double life. In 2023, Jane Doe filed a lawsuit against Peacock, the production company, the producer, and a host of other defendants involved in making Paul T. Goodman, alleging that the show defamed her by portraying her as sex worker. In the series, Finkelman claims his wife was a sex worker who led a sex trafficking ring with the help of her pimp boyfriend. The show included scripted scenes, with actors, as well as documentary footage of Paul. The series included a character, Audrey Munson, who Doe says refers to her. 

The trial court dismissed the suit in 2024. In December 2025, Florida’s Fourth District Court of Appeals revived Doe’s suit, holding that the series was capable of a defamatory meaning. The court also held that the miniseries was not a single publication that occurred in multiple parts, but instead that each episode was a “separate and distinct publication.” Under the single publication rule, when a plaintiff sues, there is typically one defamation claim based on the the publication of the allegedly defamatory content. Here, the court held that each episode in the series gives rise to its own cause of action, explaining: “there were six separate and distinct episodes, each involving significantly different content, statements, and dialogue.” For the makers of the series, this means having to potentially defend six different defamation causes of action, which could subject the defendants to multiple damages awards. 

The application of the multiple publication rule also impacts a jury's ability to consider the content as a whole. The makers of the series argue that the court's decision prevents the series from being considered in context and “undermines the ability of” defendants “to exercise their creativity when developing an episodic series.”

The intermediary court also held that the disclaimer—which stated that the series “should be taken as speculation or opinion”—was insufficient to dismiss the suit in its entirety. The appellate court wrote that “[i]n each and every episode, and throughout the series, Finkelman repeatedly maintained that the allegations against appellant were all true and that what was depicted in the series actually happened to him.” 

On March 11, Peacock appealed the intermediary appellate decision to Florida’s highest court. The high court's decision could have implications for defamation defendants, especially when a miniseries is involved.

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