Courtney Love Wins Twitter Libel Case

By Jenny Tsay, Esq. on January 29, 2014 | Last updated on March 21, 2019

Courtney Love has prevailed in an alleged Twitter libel case, as a jury has determined that she didn't defame her former attorney on social media.

Love was sued by her former attorney, Rhonda Holmes, for posting a tweet that insinuated Holmes was "bought off" when she dropped Love as a client, according to The Hollywood Reporter. The jury, however, apparently didn't think that Holmes proved her case for alleged defamation.

So how did jurors reach the verdict?

Public v. Private Figures

In defamation cases, public figures (like celebrities) and non-public figures are treated differently. Non-public figures generally just have to show that a false statement about them was published by another person, and that the statement caused some sort of injury (typically, to the non-public figure's reputation).

On the other hand, public figures must prove that the person making the injurious statement acted with actual malice. That basically means the person making the statement did so with intent to harm the public figure's reputation, or with a reckless disregard for the truth.

In attorney Rhonda Holmes' case, she was characterized as a limited-purpose public figure because of her connection to Love, according to The Hollywood Reporter.

Limited-Purpose Public Figure

Limited-purpose public figures are people who aren't "Lady Gaga" famous, but who are well-known (i.e., "public") with regard to a specific issue, explains the Reporters Committee for Freedom of the Press. Since Holmes was visible in the media because of her lawsuit against Courtney Love, Holmes was considered a public figure for the limited purpose of this case. As a result, Holmes had the burden of proving that Love acted with actual malice when she posted the tweet.

In her defense, Love testified that her tweet was meant to be a private direct message; after she found out it was erroneously sent to the public, she immediately deleted it. Love further argued that she truly believed Holmes had been bought off by her late husband Kurt Cobain's estate managers. Since Love made quick remedial efforts after she found out her tweet had gone viral, and since she legitimately thought she was only preaching the truth, the jury determined that Love didn't act with malice.

After Courtney Love's victory in this Twitter libel case and her history of voicing strong opinions on social media, perhaps Love will think twice before she tweets again.

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