Jones v. Dirty World Entertainment Recordings LLC

2014), is a case in which the United States Sixth Circuit Court of Appeals adopted the Roommates material development test for limiting immunity under section 230 of the Communications Decency Act (CDA).

Jones filed suit in federal district court on December 14, 2009, alleging defamation, libel per se, false light, and intentional infliction of emotional distress under state tort law.

[4] Richie and Dirty World moved to dismiss the case for lack of personal jurisdiction, and for judgement as a matter of law, claiming that Section 230 of the CDA gave Dirty World, as a provider of interactive computer services, immunity from suit over material authored by third parties and published on the website.

The district court denied these motions, concluding that a publisher, by "ratifying or adopting the posts" by addition of comments and invitation of further material would lose their immunity.

In an unusual turn of events, while her civil lawsuit remained pending, on March 29, 2012, plaintiff Sarah Jones was indicted by a Kenton County grand jury which charged her with a felony count of "Sexual abuse in the first degree" and "Unlawful use of electronic means to induce a minor to engage in sexual or other prohibited activities".

[5] On October 8, 2012, Sarah Jones pleaded guilty to felony custodial interference and misdemeanor sexual misconduct.

"Sarah Jones is only seeking damages prior to her relationship with [the high school student]," writes lawyer Eric Deters in the court filing requesting a January 2013 trial.