It's time for Popehat's Second Annual "Censorious Asshat of the Year" poll.

The rules of eligibility are arbitrary and capricious, but here are a few: (1) it has to be someone we've written about, (2) it has to be someone whose censorious behavior has a certain spark that elevates it above the mundane, and (3) it can't involve someone I represented, or for that matter anyone currently threatening to report me to the U.N. for hate crimes or whatever.

Here, in reverse chronological order, are the candidates.

Robert Alistair McAlpine, Baron McAlpine of West Green, who reacted to a false and vile news report by threatening not only the network that issued the report, but people who who merely repeated it on Twitter. In Aggravation: Had his attorneys issue Maoist self-criticism forms and suggest that anyone who mentioned the story should fill them out. In Mitigation: Was genuinely wronged by incompetent BBC reporting.

Matthew Overstreet of Casey Movers, who immolated his company's brand with foolish defamation threats against a bad Yelp review. In Aggravation: expressly bragged about dragging someone to a distant court. In Mitigation: He's obscure, pitiful, and has largely retreated.

Craig Brittain of "Is Anybody Down?", who used a frivolous and barely coherent DMCA notice to try to censor Popehat posts about his vile fraud scheme. In Aggravation: A thoroughly despicable fraudster and purveyor of involuntary porn designed to abuse and humiliate. In Mitigation: None.

The Reading University Student Union and its leaders Kara Swift, Kath Davey, Richard Silcock, and Ceri Jones, for pursuing disciplinary proceedings against a student group for displaying a pineapple named Mohammed, on the grounds it caused offense. Sorry, "Offence." In Aggravation: Betraying a proud heritage, contributing substantively to the decline of Western Civilization in favor of an imagined right not to be offended. In Mitigation: They very likely have never been taught any better.

Attorney Charles Carreon, who in an ongoing saga this year sent a bumptious and frivolous defamation threat to a popular webcomic, and when met with ridicule and satire, retaliated with frivolous federal litigation seeking to interfere with a charitable campaign that offended him. Also threatened a blogger for satirizing him and wrote to that blogger's employer. In Aggravation: Purports to be an internet lawyer and a defender of freedom, despite having no apparent grasp of the internet and an abiding hatred of freedom. In Mitigation: It's rubble-bouncing at this point, and his asshattery resulted in major donations to good causes.

Larry Bodine of Lawyers.com, who reported lawyers to Twitter for spamming when they used a marketing hashtag to comment on a vapid legal marketing event. In Aggravation: He and his ilk are making the legal profession, no bed of roses to begin with, measurably more awful. In Mitigation: It seems as if this was a passing fancy between feckless eructations of marketing-gibberish rather than a long-term thing.

The University of California's Advisory Council on Campus Climate, Culture, and Inclusion, which issued a broad-based recommendation for patently unconstitutional campus hate speech laws, addressing the First Amendment issues with an imperial hand-wave: “The Team recognizes that changes to UC hate speech policies may result in legal challenge, but offer [sic] that UC accept the challenge.” In Aggravation: By example, teaching university students to be stupider and more censorious. In Mitigation: Irrelevant, even for a university advisory committee.

John Rocker, brought in to WorldNetDaily to add gravitas, who offered a nearly perfect articulation of the ridiculous viewpoint that criticizing someone is a form of censorship, a long-standing Popehat bugaboo. In Aggravation: He's being a dick about people being a dick about people being a dick, and the recursion is giving me a headache. In Mitigation: Who?

Boston Mayor Thomas Menino, for threatening — albeit briefly — to bar Chick-Fil-A from Boston because its owners have regrettable views on gays and gay marriage. In Aggravation: Overtly threatened abuse of government power. In Mitigation: A born politician, he doesn't mean anything he says, and likely lacks the ability to govern his words or actions.

Sinclair Community College President Steven L. Johnson, for explaining that protesters at his state-run school are prohibited from using protest signs because of 9/11 and Virginia Tech. In Aggravation: Invoking the name of honored dead to suggest Americans should cower at the prospect of misspelled and poorly thought-out signs about Veganism and capitalist pigs or something. In Mitigation: After prolonged exposure to the academic environment, incapable of thinking like a normal person.

The Olympic Establishment, for pestering and insulting knitters and policing the pronouncements of publicans, purportedly in an effort to wring every last drop of lucre out of human athletic achievement. In Aggravation: Don't mess with fries, fuckers. In Mitigation: If we'd turn the damn TV off and stop buying the geegaws, they'd stop.

Raanan Katz, who is remarkably photogenic if you find Jabba the Hutt alluring, embarked on a legal campaign against people publishing his picture and writing about him, including saying that pointing to the alleged defamatory blogs might itself be defamation and arguing that representing people he's suing is itself actionable. In Aggravation: He thinks his money ought to make him immune to criticism. In Mitigation: He seems really quite sensitive. There should be some kind of program for that.

Berkeley Chief of Police Michael K. Meehan, who disagreed with a story written about his department, and so sent a police officer to the home of the journalist at 12:45 a.m. to ask that it be changed. In Aggravation: That's some straight-up stone-cold thuggery. In Mitigation: the article apparently hurt his feelings; it's possible that in Berkeley that's against the law.

Brett Kimberlin, a convicted perjurer and bomber who abused the justice system by seeking and obtaining "peace orders" prohibiting blogger Aaron Walker from writing about him, a legal atrocity that was only overturned with great effort. In Aggravation: Kimberlin engaged in a campaign of bombing terror, wounded a man so badly that he later took his own life, laughed off the judgment against him for years, and now thinks that the law should prevent people from writing about him. In Mitigation: Nothing. Not a damn thing. Nothing at all. Except this. Maybe.

The Lincolnshire Police, who threatened John Richards with arrest if he did not take down a letter-sized piece of paper in his window bearing the slogan "religions are fairy stories for adults." Because feelings! In Aggravation: Part of the vanguard of the sad decline of a great culture. In Mitigation: Would no doubt have been extremely polite and gentle in arresting Mr. Richards for that mean piece of paper.

The Legislatures of Arizona and Connecticut, both of which toyed with trend-humping, foolish, overbroad, and badly drafted "cyberbullying" legislation in an effort to prevent people from being mean on the internet. In Aggravation: They took oaths of office to uphold the Constitution. In Mitigation: Nobody expects them to keep those oaths.

Here is the poll. One vote only. The poll closes midnight on the 31st.

[poll id="4"]

It's time, once again, for the Popehat signal, lit to seek help for a blogger threatened with a censorious lawsuit. I'm seeking national First Amendment counsel and local counsel in Nebraska.

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In early October I announced that I would be joining Ron Coleman in a pro bono defense of Patrick Frey of Patterico's Pontifications and his wife Christi Frey in response to a federal lawsuit filed by Nadia Naffe here in the Central District of California.

Today I write to offer pleadings for anyone interested in the case, and a pleasing update regarding its status. As long as litigation continues, I'll refrain for both prudential and stylistic reasons from arguing our case here, other than to say we continue to believe the case is an abusive and meritless attempt to retaliate against protected speech. As a result, I won't be explaining the motions or legal theories, or helping you decipher legalese. You're on your own. Sorry.

The Documents

The following are conformed copies of the relevant documents, all filed publicly on PACER:

The Complaint

Ms. Naffe's Complaint

The Motion to Dismiss:

Our Motion To Dismiss

Ms. Naffe's Opposition To Our Motion To Dismiss

Our Reply In Support of Our Motion To Dismiss

The Anti-SLAPP Motion:

Our Anti-SLAPP Motion

Ms. Naffe's Opposition to the Anti-SLAPP Motion

Ms. Naffe's declaration and her exhibits A and B In Opposition To the Anti-SLAPP Motion

Our Reply In Support of the Anti-SLAPP Motion

Mr. Frey' Declaration In Support of the Reply, With Exhibits

Our Objections to Ms. Naffe's Evidence

The Notice of Dismissal

Ms. Naffe's Notice of Dismissal Of Her Claims Against Mrs. Frey, and of Certain Claims Against Mr. Cooley

The Update

As you can see, Ms. Naffe dismissed all claims against Mrs. Frey in response to our motions.

Today I appeared before Judge George H. Wu on our motions. His written tentative ruling is attached here. Note, as stated in footnote 1, that he treats allegations of fact in the Complaint as true for purposes of the motion to dismiss, as is appropriate; that's not a finding that the allegations are true. Many are not.

In brief, Judge Wu agreed with us that the Complaint failed to state a claim under 42 U.S.C. section 1983 because the facts alleged do not show that Mr. Frey was acting "under color of state law," as is required under that statute. After argument, he gave Ms. Naffe what he described as "just one chance" to amend — that is, he gave her a chance to file an amended complaint to see if she could plead facts sufficient to satisfy the requirements of Section 1983. Generally judges err in favor of giving a chance to amend.

Judge Wu did not reach the anti-SLAPP motion or the state law claims it addresses Rather, he questioned — on his own, not at our urging — whether Ms. Naffe could satisfy the damage cutoff for diversity jurisdiction, which is one of her asserted bases for federal jurisdiction. To the extent Ms. Naffe relied upon federal question jurisdiction based on her Section 1983 claim, Judge Wu indicated he would exercise his discretion to refuse to extend supplemental jurisdiction over the state law claims. In other words, Judge Wu questioned whether a federal court should hear the state claims at all. That will undoubtedly be the subject of the next set of motions.

I'm pleased that Ms. Naffe dismissed all claims Mrs. Frey in response to our motions. Although the case continues, I'm also pleased with this result, and look forward to challenging Ms. Naffe's amended complaint to vindicate the crucial First Amendment issues involved. Patrick's trying a case, so you probably won't get an update from him any time soon.

A Note About Sarcasm

I'm only going to address one minor issue in the briefs and the tentative ruling, because it involves me and this blog. In March, well before Ms. Naffe sued and I appeared in this case, I wrote a post about Ms. Naffe's threats against Mr. Frey. In that post, referring to Mr. Frey's point-by-point questioning of Ms. Naffe's accusations against James O'Keefe, I dropped this line:

The defense attorney in me is tempted to say that this is the most thorough consideration of exculpatory evidence that I have ever seen from a Los Angeles County Deputy District Attorney, but that would be uncouth, so I will not, and you should definitely forget that I brought it up.

I thought that this was self-evidently a joke, a friendly swipe by a snarky criminal defense lawyer talking about a prosecutor. I was rather surprised to see both Ms. Naffe's counsel and — in response – the judge seem to take it literally. Such are the hazards of sarcasm. Or maybe I should say, as I always do to my wife, kids, law partners, and anyone who will sit still, that nobody understands me.

So a ton of people have emailed or tweeted me this Washington Post story about a contractor suing a homeowner over a bad review on Yelp. It's been covered elsewhere, so I just want to make a few comments about it:

1. I agree with Brian Wolfman that the article's claim that such suits are "growing" appears to be part of the growing trend of unsubstantiated trend-story ass-ertions.

2. I've talked before about lawsuit threats against online reviewers that appear clearly malicious and frivolous, in that they target opinion or fail to specify what facts are allegedly misstated. The suit at the core of this article appears distinguishable: the plaintiff specifies particular damaging factual statements, not opinions or characterizations, that are false — for instance, that the business invoiced the defendant for work not performed, or that the business stole jewelry. Perhaps ultimately the plaintiff will not be able to prove that these were false statements, or that they damaged his reputation, or that the defendant had the requisite mental state — but at least the plaintiff has alleged particular false statements of fact.

One of the early inquiries in a defamation case is whether the complaint cites statements that are susceptible to defamatory meaning — that is, whether the plaintiff is suing based on alleged false statements of fact, on the one hand, or opinions, characterizations, rhetoric, or hyperbole, on the other hand. Non-frivolous complaints by competent lawyers carefully lay out specific false factual statements with sufficient context to show that the statements are not mere opinion or bluster. Courts will look to context to determine whether a statement is one of fact (and thus, potentially, defamatory) or one of opinion or mere rhetoric (and thus not susceptible to defamatory meaning). Traditionally courts have said that in the context of political debates and discussions of litigation, statements are more likely to be interpreted as being opinion or rhetoric, because reasonable readers are more likely to interpret the speech that way instead as an assertion of provable fact. Increasingly, courts say the same thing about expression on the internet — that reasonable people are more likely to interpret online speech as part of the rough-and-tumble of casual online hyperbole, and not as a statement of provable fact. However, even in the internet context, some statements are plainly of fact. If you claim a company performed shoddy work, that's probably opinion, but if you claim a company invoiced you for work not performed, that's quite likely a statement of fact.

3. Virginia doesn't have an anti-SLAPP statute. If it had a decent one, the defendant in this case could have forced the plaintiff to come forward and present admissible evidence supporting his claims — in other words, submit declarations and exhibits which, if believed, would show that the defendant made false statements of fact. In a case like this that already turns on specified statements of fact, it's not clear how much that would have helped the defendant.

4. The judge in the case recently issued a preliminary injunction requiring the defendant to take some expression down, and forbidding her from repeating other expression. On the one hand, the coverage suggests that the injunction is rather narrowly tailored — it seems to apply only to expression the judge found was false, like accusations of theft of jewelry and an apparently false suggestion that a prior court ruled against the contractor on the merits of his bill. On the other hand, preliminary injunctions against defamation are traditionally strongly disfavored, and I wonder what in this case possibly justified one, even if the injunction is not as egregious as the one in the Raanan Katz matter. Moreover, I found it remarkable that the plaintiff's motion for a preliminary injunction had no discussion whatsoever of the First Amendment issues or the traditionally tougher standard for defamation injunctions.

5. Despite the plaintiff's successes to date, suing over a negative comment is still very risky. This company's search engine profile will likely be dominated by results for this case.

Back in July I wrote about a lawsuit by one John Giduck against SOCNET, a forum discussing the Special Operations community. Giduck claimed he'd been defamed by SOCNET and its users, who asserted that he'd fraudulently posed as a Special Forces veteran.

Today Giduck lost part [or all - see update below] of his suit: Judge Stephen Groome of Park County District Court in Colorado granted a motion to dismiss by three named defendants. Colorado lacks an anti-SLAPP statute, so this was a plain-vanilla motion to dismiss — that is, an argument that the factual allegations in the complaint, even if true, were legally insufficient to state a claim. The judge's order, courtesy of Guardians of Valor, is here.

Judge Groome's order is quite thorough. It articulates one of the core principles of defamation actions: only false statements of fact can be the basis of a defamation claim. Hyperbole and statements of opinion can't.

It is this tension that has generated numerous cases addressing the first element of a defamation action, i.e. is the statement defamatory. Not every untrue, uncomplimentary or offensive statement concerning an individual is defamatory. Indeed, the law is settled in Colorado that the “mere use of foul, abusive, or vituperative language does not constitute defamation.” 7A Colo. Prac., Personal Injury Torts and Insurance § 32.2 (2d ed.), citing Bucher v. Roberts, 198 Colo. 1, 595 P.2d 239 (1979). Expressions of opinion, as distinguished from assertions of fact, are generally not actionable since “[u]nder the First Amendment there is no such thing as a false idea.” Gertz v. Robert Welch, Inc., 418 U.S. 323, 94 S.Ct. 2887, 41 L.Ed.2d 784 (1974). Such statements may be (and in practice almost always are) constitutionally privileged in order to safeguard the vigor and candor of public discourse. “Weighed against the individual’s right to be free from false and defamatory assertions . . . is society’s interest in encouraging and fostering vigorous public debate.” Keohane v. Stewart, 882 P.2d 1293. 1298
(Colo. 1994).

Giduck's complaint — even after he filed the amendment ordered by the court — attacked hyperbole, rhetoric, and opinion, at least with respect to these three defendants:

The statements attributed to these Defendants regarding Giduck were blunt, uncomplimentary, and probably “rhetorical hyperbole.” But they were also privileged statements of opinion protected by the First Amendment as applied in a litany of Supreme Court and Colorado appellate cases. The application of those cases is a question of law that must be addressed by this Court before the case goes any further. Dismissal of the defamation claims contained in the Amended Complaint is required for failure to state a claim upon which relief can be granted.

The Court also ordered Giduck to pay attorney fees under a Colorado statute applying to early dismissal of claims.

It remains to be seen what will happen with the other defendants [or not -- see below]. However, this is a major defeat for Giduck and a major victory for the defendants — and for freedom of expression.

Edited to add: Commenters and tipsters are telling me that the lawsuit has been dismissed against all defendants who were served. Here is a dismissal order applying the same reasoning to three other defendants who also moved to dismiss. I'll look for confirmation that there are no remaining defendants.

As I've argued before, local newspapers can display disappointing levels of competence and professionalism. Or, as the cynic in me suggests, perhaps they're simply displaying a disappointing inability to conceal lack of competence and professionalism, like their larger cousins usually can.

Nevertheless I can still be surprised, on occasion, by the complete meltdown of a local paper.

This is such an occasion.

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When Phil Buckley (who blogs at 1918.com) and his wife Kristen Buckley received a certified letter from a mover, perhaps they allowed themselves to hope, for a fleeting moment, that the envelope contained a check, or an apology for substandard service. It did not. It contained a very stupid and amateurish legal threat.

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Regular readers know that I occasionally offer pro bono legal assistance to bloggers threatened with frivolous and censorious lawsuits. When I've not been able to offer services myself, and have used this space to solicit pro bono help for threatened bloggers, I've consistently been heartened by the generosity of lawyers and non-lawyers alike.

Today I am proud to be offering pro bono services as local litigation counsel to Patrick Frey, who blogs as Patterico. One Nadia Naffe has filed a vexatious federal suit against Patrick and his wife in retaliation for Patrick's exercise of his rights under the First Amendment to the United States Constitution. The estimable and formidable Ron Coleman, who blogs at Likelihood of Confusion, will be lead counsel, and is also acting pro bono.

As a Deputy District Attorney, Mr. Frey is a professional adversary. As a blogger, he is substantially to the right of me, and though I respect his abilities and his honesty, I disagree with him more often than not. But I am honored to have the opportunity to serve him in defense of crucial free speech principles in the face of an abusive and politically motivated lawsuit.

This is exactly the sort of censorious and chilling lawsuit I would normally critique and analyze here in detail, but I will not be doing so. Though I may post occasional pleadings and motion practice, we will make our points in court.

Comments on this post are closed.

The main characters on Seinfeld are awful, awful people. That's the point of the show. Many people hated the final episode of the series because it stopped showing that Jerry, George, Elaine, and Kramer were awful, and spent an hour telling you they are awful, spoon-feeding the premise to the audience.

George Constanza may not be the worst character on Seinfeld, but he's as bad as they get. George is neurotic, narcissistic and possessed of a willful cluelessness that stands out even by sitcom standards.

In the Seinfeld episode "The Lip Reader," George is caught on camera at a sporting event eating ice cream in a messy and unflattering manner, something that is played for laughs, humiliating George. But George does not sue, or even talk about suing, the TV network that broadcasts footage of him looking foolish. Even on a show that is a broad farce about self-absorption and our capacity to justify any bad behavior to ourselves and others, a lawsuit storyline would be too farcical, distorting the character to the point of mere caricature.

This is why the imaginary George Constanza is a better and less ridiculous person than the regrettably real Ranaan Katz, owner of the Miami Heat.

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Note: our prior coverage regarding Team Kimberlin's censorious activities is here.

In our last episode of the struggle against Team Kimberlin — and for free expression without legal harassment — blogger Aaron Walker was muzzled by a Maryland judge who told him to "forget" applicable United States Supreme Court precedent, and had been arrested based on Brett Kimberlin's latest bogus claim of breach of the "peace order" he obtained from a compliant Maryland court.

The tide has turned.

First, Maryland prosecutors declined to prosecute Aaron Walker based on Kimberlin's latest bogus assertion that he'd breached a peace order by blogging.

Second, Aaron Walker — assisted by Maryland counsel Reginald Bours and ridiculously overqualified First Amendment expert Eugene Volokh — has filed an emergency appeal of the latest unconstitutionally overbroad "peace order". I'll try to comment on it next week. I've been kind of busy with comics and Bigfoot and yarn, y'all.

Third, Aaron Walker has filed a federal lawsuit against Brett Kimberlin in United States District Court in Maryland. I've pulled the documents off PACER and hosted them. You can read the complaint here and the motion for a temporary restraining order here. No exhibits — too big, sorry. I will not be commenting on this lawsuit. On several occasions I attempted to assist Mr. Walker in securing local counsel. When I've written about the case I've used other sources and never revealed a confidential communication with him, except as specifically authorized in order to ask for help. However, I feel precluded from discussing his federal case, as opposed to the state court proceedings.

More next week.

Edited to add: changed the motion document to the points and authorities rather than the notice, and redacted addresses from both, even though it's a public document.

Edited June 25 to add: A Montgomery County Circuit Court has granted an emergency motion to permit Walker to resume blogging, at least until a hearing on July 5.

Note: our entire series of posts about the Oatmeal v. Funnyjunk situation is now complied under the Oatmeal v. Funnyjunk tag.

Background: our previous coverage of the epic and (epically ridiculous) battle between FunnyJunk attorney Charles Carreon and The Oatmeal can be found here: Part I, Part II, Part III, and Part IV.

A few days ago I discussed a report — which proved true — that FunnyJunk's attorney Charles Carreon had sued Matthew Inman of The Oatmeal, IndieGoGo, and two charities in a fit of what can only be described as unbalanced, from-Hell's-heart-I-stab-at-thee pique.

Today, as promised, I'm going to talk a bit about the merits of — no, the substance of — you know, scratch that. I'm going to talk about the butthurt that Charles Carreon angrily crayoned down and chucked at a federal judge.

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One of my partners won an anti-SLAPP motion yesterday in Los Angeles. It wasn't my own client, and I didn't draft the motion, but I advised and edited, and I was very proud to be on the team. There are very few things in civil practice as satisfying as winning a SLAPP motion.

Then it occurred me: I talk about anti-SLAPP motions around here a lot, and ask people to support anti-SLAPP legislation. But I've been assuming that everyone knows what they are and how they work and why they are important. Reading commentary elsewhere suggests that's not the case.

So today, I'm going to talk about what SLAPP motions are, and how they work, and why they are important.

Edited to add: a few people have suggested that even the terminology is confusing. So, to start: SLAPP stands for Strategic Lawsuit Against Public Participation. A malicious or frivolous lawsuit that chills speech is the SLAPP; the statute employed against it is the anti-SLAPP statute, and the motion under the statute is an anti-SLAPP motion. To make things more confusing, people who should know better (like me) often sloppily refer to anti-SLAPP motions as SLAPP motions, or anti-SLAPP statutes as SLAPP statutes.

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So, approximately eleventy billion people wrote to me with tips about the story of Beaverton Grace Bible Church in Oregon and its pastor, Charles O'Neil, suing a former parishioner and her family members for negative online reviews. It's a story in my wheelhouse, but I elected to wait until I could get my hands on the primary documents — Oregon doesn't maintain court records online, it seems. Now I've got them, and can share them with you.

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A few months ago I pointed out that Andrew Wakefield had sued Brian Deer and the British Medical Journal for defamation. Mr. Wakefield, you might recall, is a widely discredited advocate for the position that vaccines cause autism, a position cherished by people who believe that the scientific method involves believing things very fervently.

In my post I predicted that Wakefield's suit would be an excellent opportunity to test-drive Texas' aggressive new anti-SLAPP statute. As predicted, Mr. Deer and the BMJ have filed an anti-SLAPP motion, which you can read in full here at Mr. Deer's web site.

A fair evaluation of the motion will take a slow and careful reading, which I will eventually undertake. For now, three points: (1) upon a quick read, it appears very strong, (2) note that Mr. Deer and the BMJ "specially appear" to file the motion, preserving their challenge to the Texas court's personal jurisdiction over them (which, hopefully, the Texas court will permit), and (3) if the court finds that the defendants have established that Wakefield's suit is premised on their exercise of protected speech (which the court almost certainly will), then the burden shifts to Wakefield to come forward with admissible evidence sufficient to prove that he can possibly prevail on his claims even in light of the relevant privileges and constitutional protections. In other words, Wakefield will be forced to come forward with actual evidence.

This is one to watch.

Thanks to Mr. Deer for the note referring me to his website and the motion.

Coeducational versus single-sex education is controversial. College administration is controversial, in an extremely tedious and petty way. The economics of running a college is more controversial the more you know about it.

Americans are a contentious people. We like to argue about controversial things.

Many of us see this as a good thing. We see it as part of our cultural heritage, our hard-earned exceptionalism, our competitive advantage.

Unfortunately, too many of us — even those of us in industries ostensibly devoted to open inquiry, like higher education — see it as a bug, not a feature. Too many of us react to criticism through abuse — actual or threatened — of America's deeply flawed legal system.

It is the job of everyone who loves freedom of expression to identify these people, call them out, and condemn and ridicule them.

Let's start today with Peace College of North Carolina and their lawyer, Catharine Biggs Arrowood of the firm Parker Poe.

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