Love Anti-SLAPP Denied In Appeals

Austin, Texas-based designer Dawn Simorangkir claimed in 2009 that Love never paid her for work and posted several “menacing and disturbing” statements about her online.

The designer, known as “Boudoir Queen,” also said Love called her a “nasty lying hosebag thief” and accused her of being a drug addict and a prostitute, according to the complaint.

The case was settled for $430,000 but Love fueled the fire once again when she made new statements against Simorangkir years later during an appearance on the Howard Stern show. Love “repeated the false allegations which had been the subject of the prior litigation and settlement” and “continued to defame [Simorangkir] even after Stern cautioned her,” Simorangkir’s appeal claims.

Further, the former Hole frontwoman posted some of the same defamatory claims on Pinterest along with new claims, the appeal says. Love filed an anti-SLAPP motion arguing her statements were First Amendment-protected activity but the appeals court disagreed.

“Defendant in this case contends that her comments on the Howard Stern show and on the internet have a relationship to the public interest in that they foster debate about the scope of freedom of expression on the internet and in other public fora,” the court wrote. “Yet, defendant presented no admissible evidence that any such debate followed either her appearance on the Howard Stern show or after her internet postings.”

If the public discussion surrounding the first lawsuit “was as vibrant as [Love] Claims, it is at least odd that defendant presented no evidence of any similar public debate following her statements which are the focus of this litigation,” the court continued.