The motion to dismiss filed by Michael Smith on behalf of Michelle Malkin and Twitchy in the Kimberlin v. National Bloggers Club, et al. (II) LOLsuit argued the one of the reasons that The Dread Pro-Se Kimberlin had failed to state a claim upon which relief could be granted was that he was defamation proof, i.e., that his reputation was so bad because of his criminal history that there was nothing that could be done to damage it any further. Judge Mason adopted that reasoning in his order dismissing Michelle Malkin and Twitchy. When Aaron Walker filed his motion to dismiss in that case, he cited that finding and Judge Mason reaffirmed it in his order dismissing Aaron from the case.
Perhaps the Gentle Reader can think of someone else whose reputation is so bad as a result of his own previous acts that he is barred from suing for defamation.