Stewart v. Karamian et al

Filing 21

ORDER: Malia Stewart's 1 Complaint against Hooman Karamian is dismissed without prejudice for lack of personal jurisdiction. Signed by Judge J. Leon Holmes on 3/13/2014. (ks) (Docket text modified on 3/13/2014 to correct the description of the document filed.) (thd).

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
WESTERN DIVISION
MALIA STEWART
v.

PLAINTIFF
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