Case Information
*1 Case 4:13-cv-00579-JLH Document 21 Filed 03/13/14 Page 1 of 1 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DIVISION MALIA STEWART PLAINTIFF v. No. 4:13CV00579 JLH
HOOMAN KARAMIAN, a/k/a NIK RICHIE;
and DIRTY WORLD ENTERTAINMENT
RECORDINGS, LLC, d/b/a thedirty.com DEFENDANTS
ORDER
Malia Stewart brings this action against Hooman Karamian, a/k/a Nik Richie, and Dirty World Entertainment Recordings, LLC, d/b/a thedirty.com, alleging that she was defamed by statements posted on a website, www.TheDirty.com. Karamian has filed a motion to dismiss for lack of personal jurisdiction and, in the alternative, for failure to state a claim. In a case involving very similar facts, the Eighth Circuit has held that posting defamatory material on the internet, standing alone, is insufficient to create personal jurisdiction over a defendant in the plaintiff’s home state. Johnson v. Arden , 614 F.3d 785 (8th Cir. 2010). The defendants cited Johnson v. Arden as controlling authority in their opening brief, but Stewart did not discuss it in her brief. It appears that Johnson v. Arden is on point and since it is binding authority, no further analysis seems needed. Pursuant to Johnson v. Arden , the Court lacks personal jurisdiction over Karamian.
Therefore, Malia Stewart’s complaint against Hooman Karamian, a/k/a Nik Richie, is dismissed without prejudice for lack of personal jurisdiction. Document #12.
IT IS SO ORDERED this 13th day of March, 2014.
J. LEON HOLMES UNITED STATES DISTRICT JUDGE