The Sixth Circuit Court of Appeals recently affirmed the
dismissal of a case against actor James Woods over a tweet he
posted during the 2016 presidential campaign. Woods, an outspoken
conservative, was sued by plaintiff Portia Boulger, who described
herself in her complaint as “a very active volunteer and
pledged convention delegate for U.S. Senator Bernie
Sanders.”
The case arose from inaccurate information shared on social
media. On March 11, 2016, Donald Trump held a Republican primary
campaign rally in Chicago. That evening, the Chicago
Tribune posted a photograph on its Twitter account of a woman
at the Trump rally giving a Nazi salute. The next day, a Twitter
user posted the photograph, together with a separate photograph of
Boulger, and a caption identifying Boulger as an organizer for
Bernie Sanders. The Twitter user wrote (falsely) that “[t]he
‘Trump Nazi’ is Portia Boulger, who runs the Women for
Bernie Sanders Twitter account. It’s another media
plant.”
