The tricky bit with this is, are you okay accepting a lawsuit from DC comics, possibly one that will drag on for years and years?
Aside from the murky nature of the law, anyone can sue anyone in the US, for more or less any reason. And unless it's complete bogus and gets thrown out at an early stage, you can cause someone a whole bunch of hurt. Who is right and wrong according to the law only marginally comes in to play.
In this case, it's not even clear to me Willingham has the right to single-handedly place something in the public domain; did no one else work on those comics? Don't they also own a piece of copyright (which they perhaps signed over to DC?) This is like the main author of an open source project single-handedly changing the license, which isn't something you can "just" do even if you wrote 95% of it (even though many small one-line contributions often don't meet the threshold of originality for copyright to apply, it's not so easy to determine where this threshold is, legally speaking, and things can get quite murky rather fast).
It's essentially the same problem Willingham has, where suing D.C. is just too time-consuming and expensive, except that Willingham can choose to sue DC or not, whereas you don't choose if someone sues you or not.
I'm very sympathetic to Willingham's plight and I'd love it if more people would just place things in public domain (or other CC licenses for that matter), but here I'm not sure if he legally can, and even if he could it's murky enough that DC most likely will sue, so practically speaking he can't anyway.