Ingraham v. Gray [1]

In August 2010, married couple Alexis and Brett Ingraham sued blogger Madeline Gray for defamation based on statements posted on Gray's website (NickerNews.net) and distributed via flyers. The Ingrahams' alleged that in a series of blog posts in 2010, Gray accused them of neglecting and abusing the horses at their farm, and that these statements were false and harmful to the Ingrahams' reputations, social standing, and profession.

Gray moved to dismiss the complaint on the grounds that the Ingrahams were being prosecuted by the Kennebec (Maine) County District Attorney for animal cruelty, attaching the State's complaints listing seven counts of animal cruelty. Gray argued that in light of the State's case, the Ingrahams had failed to assert sufficient facts to support their claim. The court rejected Gray's argument [2], asserting that the pending criminal action was not sufficient to "defeat the adequacy of [the Ingrahams'] allegations."

The Bangor Daily News reported in June 2011 [3] that the Ingrahams had been convicted of six misdemeanor counts of animal cruelty. Subsequently, Gray moved for summary judgment in the defamation case based on a theory of collateral estoppel. According to Gray's Motion for Summary Judgment [4], "a criminal conviction conclusively establishes all facts essential to the conviction and is preclusive in favor of a third party in a subsequent civil action." The Ingrahams opposed [5] the motion, arguing that the statements at issue in the case were broader than the issues in the criminal action, and that the nature of their guilty pleas in the criminal action was such that they were not precluded from arguing that the underlying factual allegations in that action were false.