4th Circuit Upholds Internet Flame War Lawsuit Dismissal on 230 Grounds–Winter v. Bassett

Winter v. Bassett, No. 03-2176 (4th Cir. Dec. 12, 2005)

This lawsuit involves one of those oh-so-messy Internet flame wars/personal disputes that prompted the creation of an anti-Steve Winter website. Winter then sued a variety of people, including the web host and various IAPs, for defamation and related business torts. In August 2003, the District Court granted several defendants’ motion to dismiss based on 230. Then, earlier this week, the 4th circuit upheld that dismissal in an unpublished per curiam opinion. This result is hardly surprising, especially given that Zeran is 4th circuit precedent. For more background on this lawsuit, see this page.