Feld v. Conway [1]

In November 2010, Mara Feld arranged for her thoroughbred gelding to be shipped to a horse farm. The horse was instead sent to a horse auction and may have been slaughtered in Canada. The horse's fate became a topic of great debate on Internet sites dealing with thoroughbred race horses and at some point Crystal Conway became involved in the ongoing online discussions. On December 11, 2010, Conway posted on her Twitter account: "Mara Feld aka Gina Holt - you are fucking crazy!"

On December 10, 2013, Feld filed a complaint [2] alleging one count of libel. Afterwards, Conway filed a motion to dismiss [3], arguing that the complaint did not state a claim upon which relief can be granted because her statement was an opinion. Conway further argued that the use of vulgarity signaled its lack of clinical or factual significance. Feld responded [4]that the statement in question was not obviously a statement of opinion, because it could be interpreted differently. Furthermore, Feld argued that the use of profanity did not transform the statement into mere opinion.

The court held [5] that the tweet had to be read in the context of the ongoing online discussion, rather than in isolation. In that context, the court found that the tweet could not reasonably be understood to state actual facts about Feld's mental state. Therefore, the complaint could not support a claim of defamation and Conway's motion to dismiss was granted.