A 1968 story in the New York Times reports that “Nona Gaprindashvili of the Soviet Union, the women’s world chess champion,” defeated seven men at an international chess tournament in Sweden, where she was the only woman in the field. In the 1983 book, The Queen’s Gambit, which tells the fictional story of an American girl who rises from humble beginnings to become a top chess player, the author mentions Ms. Gaprindashvili by name in the book’s final chapter set at a prestigious chess tournament in Moscow, noting that she had “met all these Russian Grandmasters many times before.” Netflix released a popular series based on the book which concludes as the book did with the climactic tournament. And just as in the book, Netflix invoked Gaprindashvili’s name for dramatic effect. But they changed one detail. “There’s Nona Gaprindashvili,” an announcer says, while the camera pans to an actress resembling her. “But she’s the female world champion and has never faced men.”
Gaprindashvili, now 80 years old and living in Tbilisi, Georgia, was appalled to learn that her professional accomplishments had been diminished by the series and filed a lawsuit in California last week for defamation and “false light.” To me, the case provides a good illustration of the limitations of defamation law and the reasons some states recognize a cause of action for “false light.” (I should note here that Virginia is not one of those states.)