Rhode Island Family Court v. Grant [1]

Anne Grant maintains a blog, The Custody Scam [2], where she "writes about official actions that endanger children and parents trying to protect them." Grant used the blog to write about a child custody case involving minors "Sara Doe" and "Mary Doe" (pseudonyms). The blog criticized the manner in which the Rhode Island Department of Children, Youth and Families (DCYF) handled the Doe case. In particular, Grant objected to the DCYF hearing officer's reliance on a theory known as "parental alienation syndrome" to remove the two children from their mother's custody and to place one of them with the father, who had previously been accused of sexually abusing them -- charges that the DCYF held to be unfounded. While the blog entries did not reveal the minors' identities, they did include personal information and photographs of the children.

The family court judge handling the Doe case ordered DCYF to "advise" Grant to remove "any and all written and pictoral information" relating to the children involved, and to "cease publication of the blog as it pertains to these children."

Grant objected to the order and sought to have the Rhode Island Supreme Court vacate it. In her petition, Grant argued that the family court's order violated her due process rights and was an overbroad restraint on her speech. The Supreme Court declined to hear the case without providing an explanation for its refusal, but some speculate that the court refused to review the order because it was directed at DCYF, not Grant.