Mann v. Steyn: Finally Ready For Appeal?

Way back in 2012, climate “scientist” Michael Mann, then at Penn State University, sued four defendants for defamation.  The four were commentators Mark Steyn and Rand Simberg, who had written blog posts about Mann, and National Review and the Competitive Enterprise Institute, entities which had respectively hosted the Steyn and Simberg posts.  The occasion for the Steyn and Simberg posts was that independent investigator Louis Freeh had issued a Report that had castigated Penn State President Graham Spanier for having whitewashed the conduct of the university’s assistant football coach, Jerry Sandusky, in a sex abuse scandal.  Steyn and Simberg had compared Spanier’s exoneration of Sandusky to his exoneration two years previously of the university’s star climate science professor, Mann, after the so-called “ClimateGate” emails had shown Mann deeply involved in data manipulation schemes to support the narrative of climate apocalypse.

Here we are now in 2026, more than 13 years later.  The Mann v. Steyn case has gone through a truly incredible procedural history, including multiple motions to dismiss, two appeals to the D.C. Court of Appeals (different from the D.C. Circuit Court of Appeals), a certiorari petition to the Supreme Court, a jury trial after remand (in 2024), and a bevy of post-trial motions.  I have previously had numerous posts covering this case, including the trial and subsequent developments.  My most recent post was this one from March 2025, covering decisions by the trial judge (Alfred Irving of the D.C. Superior Court) on most of the post-trial motions.  

A few days ago, on January 22, the Judge Irving finally issued a decision that appears to resolve the last of the post-trial motions.  Most notably, the judge has now put numbers on the amounts that Mann will be required to pay to Steyn and Simberg for having presented false evidence at trial and thus having put those two through the effort of disproving the false evidence.  However, the amounts are quite modest in the context of the vast resources that have gone into fighting this battle:  Mann is ordered to pay $11,404.80 to Steyn, and $16,762.82 to Simberg.

As I reported in my March 2025 post, the high point of the case for Mann came in February 2024, when the jury returned its verdict.  Although the jury awarded Mann only one dollar of “nominal” damages against each of Steyn and Simberg, it awarded $1 million of punitive damages against Steyn, and $1,000 of punitive damages against Simberg.  (National Review and CEI had previously been dismissed from the case on motions.). Mann and his media acolytes immediately took to gloating on social media about his great victory.