Jones v. Dirty World Entm’t

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The Dirty World website enables users to anonymously upload comments, photographs, and video, which Richie selects and publishes along with his own editorial comments. Jones is a Kentucky high school teacher and a member of the cheerleading squad for the Cincinnati Bengals football team. She was the subject of several submissions posted by anonymous users and of editorial remarks posted by Richie, including photographs of Jones and a statement that she “slept with every other Bengal Football player.” Jones requested that the post be removed. Richie declined. A subsequent post alleged that her former boyfriend “tested positive for Chlamydia Infection and Gonorrhea ... sure Sarah also has both ... he brags about doing sarah in … her class room at the school she teaches at DIXIE Heights." Richie's responded to the post: “Why are all high school teachers freaks in the sack?” Jones brought claims of defamation, libel per se, false light, and intentional inflection of emotional distress. The district court rejected arguments that the claims were barred by the Communications Decency Act of 1996 (CDA), 47 U.S.C. 230. A second trial resulted in a verdict for $38,000 in compensatory damages and $300,000 in punitive damages. The Sixth Circuit reversed. Under the CDA, Richie and Dirty World were neither creators nor developers of the challenged content. Jones’s tort claims are grounded on the statements of another content provider, but sought to impose liability on Dirty World and Richie as if they were the publishers or speakers of those statements. Section 230(c)(1) bars those claims. View "Jones v. Dirty World Entm't" on Justia Law