Polygram Records, Inc. v. Superior Court

In Polygram Records, Inc. v. Superior Court (1985) 170 Cal.App.3d 543, the plaintiff wine distributer claimed that comedian Robin Williams defamed him during a comedy routine in which Williams referred to an individual with the plaintiff's name as part of a joke commenting on the existence of white and red wines but the absence of "Black wines" and adding disparaging comments about Black wines. (Id. at pp. 546-547.) The court ruled that the statements were not actionable, agreeing with the defendants that the "allegedly defamatory monologue 'is not actionable as a matter of law because an obvious joke, told during an obvious comedy performance, is a form of irreverent social commentary, is not taken seriously, and thus does not affect reputation in a manner actionable in defamation.'" (Id. at p. 551.)