John Doe, No. 1 v. Hon Eddy Coleman Judge, Pike Circuit Court, 2015 SC 000408

Hickman sued anonymous Topix posters (John Does) for defamation in Pike Circuit Court, alleging publicaciones harmed his reputation and cited a transcript of posts.
John Does sought to quash subpoenas seeking their identities; the trial court denied, leading to a writ of prohibition petition.
Court of Appeals described and applied Cahill (Delaware) as modified by its Welch concurrence, limiting pre-discovery disclosure.
This Court reversed the Court of Appeals to apply Dendrite’s four-step test for anonymous defamation discovery.
The Court held Hickman must show specific falsity and other prima facie evidence under Dendrite before ordering disclosure, balancing First Amendment rights.
The case also addresses whether attorney-client privilege prevents disclosure of clients’ identities at this stage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a writ of prohibition is available to compel non-disclosure	Hickman argues proper application of Dendrite/Cahill requires disclosure only with prima facie defamation	John Does contend trial court correctly applied Cahill-style standard	Writ of prohibition is available to protect anonymity; reversal warranted to apply proper four-step Dendrite test
Whether Hickman met a sufficient prima facie showing to overcome First Amendment protection of anonymity	Hickman asserts falsity and malice with evidence as to defamatory statements	John Does argue statements are non-defamatory or insufficiently proven false	Hickman not yet shown adequate facts to prove falsity; identities not disclosed at this stage
Whether attorney-client privilege bars disclosure of client identities at this stage	Client identities are privileged communications; disclosure would reveal confidential information	Identities are not privileged; First Amendment governs anonymity	Attorney may not be ordered to reveal client identities while anonymity remains viable; once prima facie defamation is established, identities may be disclosed but not confidential communications

Dendrite Int'l., Inc. v. Doe No. 3, 775 A.2d 756 (N.J. Super. Ct. App. Div. 2001) (established four-step process for discovering anonymous speakers)
Cahill v. Cahill, 884 A.2d 451 (Del. 2005) (two-step Cahill approach; but four-step framework is preferred for Dendrite alignment)
Welch v. American Publishing Co. of Kentucky, 3 S.W.3d 724 (Ky. 1999) (partial concurrence; discussed summary-judgment flavor in falsity analysis)
McCall v. Courier-Journal & Louisville Times Co., 623 S.W.2d 882 (Ky. 1981) (defamation elements; standard for fault for public figures)