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Be Careful What You Say – Man United Footballer Scores Libel Judgment in Swedish Court

On January 9, 2017, the Varmland District Court in Sweden called a foul on Ulf Karlsson, the former Swedish national track and field team manager, finding him liable for aggravated libel for remarks made about Manchester United footballer Zlatan Ibrahimovic. At a panel hosted by the New Sporting Historical Societies Sports Café in Karlstad, Sweden, Ulf Karlsson suggested that Ibrahimovic had used performance-enhancing substances during his stint with the Juventus Football Club.

Ibrahimovic is the much-heralded striker who made his international debut as a member of Sweden's national team in 2001, serving as captain until his retirement from international play in 2016. In the intervening years, Ibrahimovic starred on several professional football clubs in top leagues in Sweden and Europe. Immediately following the accusations lobbed at him at the panel, Ibrahimovic cleared the alleged errant pass, claiming that he has never tested positive for doping.

Ibrahimovic began his career at Swedish club Malmo FF in the 1990s, and ultimately made his way to play for Juventus F.C. in Turin, Italy between 2004 and 2006.  Prior to Ibrahimovic's arrival at Juventus, the football club had shaken off years of disappointing results by winning three Serie A titles, among other championships, in the late 1990s, leading some to allege that their methods to achieve such success were out of bounds.  In 1998, following an investigation by local officials, the club premises were raided and investigators found 281 different types of pharmaceutical substances (the vast majority of which were not on the banned list), prompting additional inquiries.  In 2002, the investigation culminated in a trial of several team officials, with an Italian court convicting the former team doctor of supplying players with the banned substance EPO between 1994 and 1998. On appeal, however, the team doctor's conviction was overturned. 

Against that backdrop of events, Karlsson suggested that Ibrahimovic must have doped during his time with Juventus. "Zlatan went up 10 kilograms of muscle during the period at Juventus," Karlsson said at the panel. "It was pretty fast. In one year he did it." Karlsson took another free kick by making similar comments in an interview with a local newspaper, saying "Zlatan gained 10 kilos of muscle in six months at Juventus. That is impossible in such a short time."

Though Karlsson later issued an apology to the striker, Ibrahimovic refused to swap jerseys with Karlsson and brought claims against the former Swedish national coach for aggravated libel, claiming that the coach's words were intended to cause serious injury. The judge found Karlsson's comments at the panel to be offsides, ordering Karlsson to pay a fine of 24,000 kronor (about $3,400).  In one excerpt, the verdict read: "Even if his remarks do not contain a direct accusation that Zlatan Ibrahimovic had taken steroids, the court finds that these remarks, given the context in which they were made, cannot be taken any other way than to give the impression that Zlatan Ibrahimovic would have taken steroids during his time at Juventus."  However, the court sidelined the claim over statements made during Karlsson's newspaper interview, as it appears that Swedish law offers more protection to remarks made to journalists. Although Ibrahimovic sought an additional penalty against Karlsson for court costs, the court ruled that both parties should bear their own costs in this case. 

With his victory in the courtroom and prolific goal scoring this season (e.g., Ibrahimovic is in the running for the Golden Boot award for the Premier League's top scorer), Ibrahimovic certainly hopes his winning ways continue, especially as Manchester United is currently sixth in the Premier League standings, a few spots out of a vaunted Champions League slot.

© 2020 Proskauer Rose LLP. National Law Review, Volume VII, Number 41


About this Author

L. Robert Batterman, Labor, Management, Sports, Attorney, Proskauer, Law Firm

A partner since 1974, Bob Batterman has considerable experience representing both individual employers and multi-employer groups in union relations and collective bargaining. Much of Bob’s time is spent in day-to-day contact with clients, often in “crisis” situations where a rapid resolution of union-related problems is vital.

Bob is a senior member of our nationally recognized Sports Law Group, serving as labor counsel to the National Hockey League, Major League Soccer and the National Football League. He has extensive experience in collective...

Michael Cardozo, Commercial Litigation Attorney, Proskauer, Law Firm

Michael A. Cardozo is a Partner in Proskauer’s Litigation Department and the former Corporation Counsel for the City of New York. As the city's 77th and longest serving Corporation Counsel, he was the city’s chief legal officer, headed the city's Law Department of more than 700 lawyers, and served from 2002 through 2013 as legal counsel to Mayor Michael Bloomberg, elected officials, the city and its agencies.

Michael’s experience managing large litigations in both the private and public sectors provides him with unique insight into litigation assessments, risk management and mitigation issues. In his role as head of the New York City Law Department, he effected numerous changes that resulted in significantly increased efficiency. He achieved this by greatly expanding the use of technology and statistical data allowing for effective risk/cost analysis of cases.

Robert L. Freeman, Technology, Media, Sports, Attorney, Proskauer, Law Firm

Robert E. Freeman is a Partner in the Corporate Department and a member of the Sports Law Group and Technology, Media & Communications Group.

Rob began his career as an intellectual property litigator before shifting the focus of his practice to intellectual property-related transactions. Today, he helps lead a team of media, sports and entertainment attorneys representing clients such as Time Warner Cable, Discovery Communications, the WTA, the Orlando Magic, Scripps Networks, Armstrong Cable, the PAC-12, Insight Communications and CBS Sports. Rob’s work for these clients...

Howard Ganz, Sports, Employment Attorney, Proskauer, Law Firm

Howard Ganz is co-head of the Sports Law Group and former co-Chair of the Labor & Employment Law Department.

Howard represents and counsels clients with respect to a wide variety of labor and employment matters, such as employment discrimination, sexual harassment, wrongful discharge, defamation, breach of contract, discipline, and large-scale reductions-in-force. His litigation experience has run the gamut, from single plaintiff lawsuits to major class actions, in federal and state courts in New York and elsewhere. The clients Howard has represented include the National...

Wayne D. Katz, Finance, Sports, Attorney, Proskauer, Law Firm

Wayne D. Katz is a Partner in the Corporate Department, specializing in the sports industry.

Wayne's experience includes the representation of the National Basketball Association and National Hockey League in their various corporate matters, including team ownership transfers and team financings. Major transactions he has worked on for the leagues include the NBA’s purchase and sale of the New Orleans Hornets; the NBA's grant of expansion franchises to Toronto, Vancouver and Charlotte; the NHL's grant of expansion franchises to Nashville, Atlanta, Columbus and Minnesota; the NBA’s $...