John Doe No.1 v. Burke

John Doe No.1 v. Burke (May 29, 2014)


STATUS: Appeals Court upheld Anti-SLAAP motion.


In its first decision to interpret the District of Columbia's Anti-SLAPP law, the D.C. Court of Appeals quashed a subpoena to an anonymous Wikipedia user sued for defamation.  The D.C. statute goes further than other jurisdictions in protecting anonymous speech by affording anonymous defendants the ability to file special motions to quash subpoenas for their identities. The Court first held that it had jurisdiction to hear an appeal from the trial court's denial of the motion.  On the merits of the motion, the Court held that plaintiff, an attorney, was a public figure who failed to show that edits to her Wikipedia page were made with actual malice.


Opinion:
http://www.dccourts.gov/internet/documents/13-CV-83.pdf