As the bounty case now focuses on the defamation case filed by Saints linebacker Jonathan Vilma against Commissioner Roger Goodell, one of the main arguments will become whether Goodell acted recklessly when giving credence to anything said by former Saints assistant Mike Cerullo.
Recklessness becomes important because Vilma is a public figure. He can prove defamation only if he shows that Goodell knew that what he was saying about Vilma was false, or that if Goodell acted with reckless regard as to the truth or falsity of the statements.
Chris Mortensen of ESPN reports that Vilma soon will file a memo that shows the league and the Saints coordinated their security efforts in connection with the termination of Cerullo’s employment. This meshes with a strong allegation contained in a recent Vilma filing: “The Saints were so concerned about Cerullo’s stability, as Goodell also knew, that, when Cerullo was terminated, Saints head coach Sean Payton also was forced to obtain police protection at his house for fear that Cerullo would seek some type of retribution.”
The argument will be that the NFL knew that there were concerns that Cerullo would not react well to the team’s decision to fire him. Which means that anything he later said about the Saints should be taken with a proverbial grain of salt.
But Vilma now contends that, as to the allegation that he placed a bounty on Kurt Warner, Cerullo was Goodell’s only source. In Vilma’s defamation case, Goodell and the NFL will have to show that Cerullo was reliable, despite any inherent biases.