Courtney Love Wins Crazy Twitter Defamation Suit by Her Ex-Lawyer

By Casey C. Sullivan, Esq. on February 05, 2016 | Last updated on March 21, 2019

Twitter can be hard. Politicians accidentally tweet out compromising photos, prosecutors embarrassingly follow porn stars, and Courtney Love accidentally accuses her attorney of being "bought off."

And Love's Twitter mishaps are just the tip of the crazy iceberg that floated in to California's Second District Court of Appeals after Love's former attorney unsuccessfully sued her for the allegedly defamatory tweet.

Someday You Will Tweet Like I Tweet

Courtney Love, lead singer of Hole, all-around crazy rock-n-roll icon, and wife to the late Kurt Cobain, isn't known for keeping her mouth shut. But, when it comes to criticizing her attorney on Twitter, everything was an accident, Love claims. In 2010, Love was concerned that one of her attorneys, Rhonda Holmes, had "vanished." Love (whose Twitter handle is @Courtney), tweeted out the following to two "wannabe reporters:"

I was fucking devastated when Rhonda J. Holmes, Esquire, of San Diego was bought off @FairNewsSpears perhaps you can get a quote.

She thought, however, that the tweet was private and claims that she never meant Holmes was actually bribed, simply "compromised." Holmes sued, for libel per se. A jury found that the statement was false and injured Holmes' professional reputation, but that there wasn't evidence that Love knew it was false.

Holmes appealed and the appellate court affirmed the jury's verdict. They rejected Holmes' argument that "bought off" could only have meant bribed. Were the statement a false claim of bribery, it would have constituted actual malice as a matter of law, as required of public figures claiming defamation.

But, the court explained, to show "reckless disregard for truth," Holmes would have to show that Love herself seriously doubted the truth of her statements. But Love testified that she did not mean "bought off" to have its dictionary definition. Rather, she thought that being "bought off" didn't mean "someone walked up and handed you a bunch of cash." To Love, that's not "how it's done." According to Love, being bought off means, somewhat idiosyncratically, being threatened or compromised, causing Holmes to abandon Love.

Viewed in the context of Holmes' year-long lack of contact with Love, the court found such testimony amounted to substantial evidence supporting a finding that Love lacked malice and knowledge that her statements were false.

Wait, Bought Off?

So, back to the underlying issue. Why was Love concerned that her lawyer was "bought off" in the first place? According to the court, after Kurt Cobain's suicide, Love "came to believe that various persons had defrauded her, her daughter, and her husband's estate of millions of dollars." She hired Holmes and her firm, Gordon & Holmes, to "go after" whoever was responsible.

Holmes brought in a forensic fraud economist, drafted press releases, gathered documents, and otherwise pursued a case wherein $30 million or more was thought to have been taken from Love and her daughter, Frances Bean Cobain. Love sent more than 80 boxes of documents to Holmes and expected her to file a complaint in May of 2009.

But Holmes never did. Instead, Holmes told Love that Love's former attorney had threatened her, that her computer had been hacked, her phone had been tapped, and that $140,000 had been stolen from her bank account. Behind Love's back, Holmes wrote to Love's daughter. That letter contained what the court described as "personal confidences" and claimed that Holmes represented Frances and her family (she did not) and that Frances had been "the unfortunate victims of a very large and very scary conspiracy."

Then Holmes's representation more or less stopped. Holmes claims that Love cut off all contact. Love claims that Holmes quit, or vanished. Holmes sent an email in 2009 saying that she "DID NOT QUIT," but never contacted Love after that point. Until, that is, the defamation suit.

Was there a conspiracy? Had Holmes been silenced by a shadowy cabal of ex-Nirvana members and Universal Music execs? Frankly, who the heck knows. The background described in Holmes and Love's lawsuit sounds as bonkers as Kurt Cobain truther conspiracies.

But crazy as the story might be, at least one thing is settled: Courtney Love's tweets weren't per se defamatory. And that's about the only clarity we'll get from this suit.

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