Mike Lindell to Pay 2.3 Million, Accusing Coomer of Treason

Highlights

Federal judge grants summary judgment: Lindell defamed Smartmatic via repeated false statements
Court identifies 51 specific defamatory statements spread by Lindell across media and documentaries
U.S. Judge Rules Lindell Made 51 False Claims; Jury Must Now Assess Actual Malice
Smartmatic seeks “nine‑figure damages” (≈ $1.5 billion) and presumption of damages if malice is proved
Lindell held in contempt of court for failing to turn over financial and analytics records

The Core Facts

Smartmatic, which provides election technology (including ballot marking systems), sued Mike Lindell and MyPillow in 2022 for defamation over Lindell’s high‑profile public claims that Smartmatic’s machines in Los Angeles County had been manipulated to shift votes from Donald Trump to Joe Biden.

On September 26, 2025, U.S. District Judge Jeffrey Bryan issued an order granting (in part) Smartmatic’s request for summary judgment on the threshold question: whether Lindell’s statements were defamatory as a matter of law. The judge found that the record contains 51 statements by Lindell that are false and defamatory, and that “no reasonable trier of fact could find that any of the statements at issue are true.”

However, Judge Bryan declined to resolve the separate question of actual malice at this stage. Instead, he held that genuine fact disputes remain over whether Lindell made those statements “with knowledge that they were false or with reckless disregard for their truth or falsity.”

Because Smartmatic is a public figure or (at least) asserting claims about a public matter (the integrity of elections), the standard of actual malice must be met before damages can be awarded.

Judge Bryan also presumed that Smartmatic is entitled to damages for reputational harm — meaning that if a jury later finds malice, Smartmatic’s damages burden is eased.

Smartmatic is seeking up to $1.5 billion in damages.

A complicating factor: Lindell has been held in contempt for failing to produce requested discovery, including MyPillow’s website analytics and financial statements (for 2022–2023), which Smartmatic argues are relevant to Lindell’s motive and ability to pay.

Lindell contends that he lacks the means and that much of the case is an instance of “lawfare” against him.

Background: Lindell, Smartmatic & the Election Fraud Claims

Mike Lindell

Mike Lindell, founder of MyPillow, became one of the most vocal and visible promoters of conspiracy theories alleging that the 2020 election was stolen. He produced documentaries (e.g. Absolute Proof) and made repeated public appearances claiming voting machines were manipulated.

His tactics often included embedding ads or discount codes for MyPillow in his election‑fraud messaging, which Smartmatic argues shows a financial motive tied to defamation.

Lindell has been involved in other lawsuits: notably, in June 2025, a jury in Colorado found that he defamed Eric Coomer, a former Dominion employee, and awarded Coomer $2.3 million.

He is also contending with a $5 million arbitration award (from a dispute over purported “China interference” data) that he has tried to avoid paying — and recently succeeded on procedural grounds.

Lindell has reasserted residency in Minnesota, fueling speculation about a gubernatorial run.

Smartmatic

Smartmatic is a company that supplies election infrastructure technology. Its U.S. presence in 2020 was narrow: its machines were used in Los Angeles County (the only U.S. client for its devices in that cycle).

Smartmatic has been aggressive in litigating defamation claims tied to 2020 election misinformation. It has already settled with Newsmax and One America News (OAN) over false claims aired about its role in the election.

Smartmatic is also pursuing a major defamation suit against Fox News.

In their complaint, Smartmatic asserts that Lindell’s repeated false accusations harmed its reputation and business, and that Lindell leveraged his campaign to promote MyPillow sales, which they argue shows motive.

Legal Context: Defamation, Public Figures & Actual Malice

Defamation & Summary Judgment

Under U.S. defamation law, a plaintiff must show (1) a false statement presented as fact, (2) publication to a third party, (3) fault (depending on status of the plaintiff), and (4) damages. Because Lindell was making statements about a company tied to public interest (elections), Smartmatic must satisfy the higher standard of “actual malice.”

A defendant may ask for summary judgment (i.e. dismissal without trial) if no genuine factual dispute remains. Judge Bryan’s ruling that no reasonable factfinder could find Lindell’s 51 statements true is a strong finding on the falsity element.

However, because malice is inherently a fact-intensive inquiry (subjective state of mind, recklessness), courts are often reluctant to grant summary judgment on that element when there is competing evidence. That is precisely what Judge Bryan did: deny summary judgment on malice.

The Actual Malice Standard

The doctrine of actual malice stems from New York Times Co. v. Sullivan (1964), which requires that a public-figure plaintiff show the defendant either knew the statement was false or acted with reckless disregard for its truth.

Reckless disregard is a high bar — essentially a “subjective” standard: not merely negligence, but can’t just be careless. Courts typically look at whether the defendant had serious doubts about the truth, or ignored obvious signs of falsity, or failed to investigate when there was reason to.

In this case, Lindell’s defense claims he held an “unwavering belief” in his assertions. That assertion creates factual tension over whether he genuinely believed the statements (in which case malice is harder to find) or whether his belief was a cover for disregard of evidence.

Presumed Damages & Motive

Because Smartmatic is a public-figure (or at least a company in the public-interest domain), they often must show “actual damages” (reputational harm, lost business). But courts sometimes adopt presumptive damages when defamation is established. Here, Judge Bryan has presupposed that Smartmatic is entitled to damages for reputational harm, shifting the burden toward Lindell to rebut or limit.

Smartmatic will likely probe Lindell’s finances, his MyPillow marketing strategy embedded in his election rhetoric, and his internal communications for evidence of motive or awareness of falsity. The court already indicated that Lindell’s profit motives (e.g. linking pillow sales to election claims) are relevant to malice.

Implications & Significance

For Election Misinformation Accountability

This ruling marks a notable escalation in legal accountability for election disinformation. Courts are being willing to parse conspiracy claims and make findings that certain statements are outright false. Lindell’s case shows that even prominent voices with large platforms can be held to account if their statements transgress the bounds of verifiable fact.

It also signals that companies like Smartmatic, which have historically been more passive actors in election discourse, are increasingly pushing back via legal means. The Smartmatic‑Lindell litigation sits alongside the larger wave of defamation suits involving Dominion, Fox News, Newsmax, OAN, and others.

Risks & Chilling Effects on Speech?

Critics may argue that aggressive defamation suits against public discourse risk chilling speech, particularly in contentious political contexts. But because the actual malice standard remains high, courts are generally wary of chilling protected speech. Lindell’s defense may lean heavily on free speech arguments — that he was exercising his right to debate election issues. That said, when claims are demonstrably false and made recklessly, courts may be less tolerant.

Strategy & Litigation Tactics

Smartmatic’s approach—securing a summary judgment ruling on falsity and pushing the burden onto Lindell for malice—is a shrewd litigation strategy. It narrows the live issues, potentially corners Lindell into a difficult position (malice is a notoriously hard standard to rebut).

Lindell’s contempt sanction for noncompliance in discovery could further jeopardize him, especially if the court imposes adverse inference instructions (i.e. assuming missing evidence would have been harmful to him).

Valuation, Damages & Enforcement

Even if a jury finds malice, Smartmatic must still prevail on damages determination, causation, and enforceability (especially if Lindell claims inability to pay). With damages in the nine‑figure range, collecting may require piercing through MyPillow’s assets or structure. Lindell’s claims of financial ruin or inability to pay may complicate enforcement.

Also, appellate review will be intense, especially given the stakes over actual malice doctrine and First Amendment tensions.

What’s Next

Discovery & Evidentiary Phase. Smartmatic will dig into Lindell’s internal records, communications, MyPillow marketing data, and other documentation to show that Lindell knew or recklessly disregarded the falsity of his claims.
Trial on Malice & Damages. The jury (or factfinder) must resolve whether Lindell’s state of mind satisfied the actual malice standard, and if so, how much in damages to award.
Potential Sanctions / Adverse Inferences. The court might impose consequences for Lindell’s discovery failures, thereby strengthening Smartmatic’s case.
Appeals. Regardless of the outcome, Lindell is almost certain to appeal any adverse decision, especially on malice findings or constitutional arguments about free speech.
Parallel Litigation. Smartmatic’s case is one among many defamation suits tied to the 2020 election. How courts handle malice, damages, and discovery in Lindell’s case will influence future cases.

Conclusion

Judge Bryan’s ruling is a significant milestone: it formally holds Lindell liable for defaming Smartmatic by making dozens of false assertions. At the same time, by reserving the question of actual malice, the decision underscores how difficult it is, under U.S. law, to win full damages against a public figure. The coming trial on malice and damages will be a high-stakes confrontation over how courts police misinformation in democratic discourse.

This case is likely to become a bellwether: not just for Lindell and Smartmatic, but for election litigation, defamation law, and the balance between protecting reputation and safeguarding robust public debate.