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Reason
Reason
Politics
Eugene Volokh

Alleged Neo-Nazi Loses Libel Lawsuit

From Weaver v. Millsaps, decided Wednesday by the Georgia Court of Appeals, in an opinion by Judge C. Andrew Fuller, joined by Judges Anne Elizabeth Barnes and Benjamin Land:

After Michael Weaver and others acting at his behest posted negative Google reviews of Valerie Millsaps's frame shop business, she published a response, calling Weaver a Neo-Nazi and known felon who was targeting her business and had "threatened to kill other shop members."  …

Millsaps and her husband own a framing shop in Cartersville. One day in June 2022 while Millsaps was driving her company van, she saw Weaver standing on the street holding a sign that appeared to be antisemitic. Millsaps "displayed [her] middle finger" at Weaver. Weaver, having seen the business logo on the van, published a post on his personal blog asking his followers to leave negative Google reviews of the business. Within 12 hours, multiple negative reviews appeared on the business's Google review page. Weaver subsequently thanked his supporters who had left the reviews and stated, "I'm just getting warmed up! … Total f__king war!"

In response, Millsaps posted her own comment on her business's Google review page:

My business is being targeted by a Neo Nazi and a member of the KKK. Please disregard the reviews. None of those profiles have ever entered my shop. I am being harassed and bullied by Michael [Weaver]. A known felon of hate crimes. He has targeted many businesses in our town. I refuse to be intimidated by him and his hate literature that he has left at my shop and my home. He has threatened to kill other shop members and flooded their Google reviews with harassing, untrue reviews. You can decide to try my shop and let my experience speak. Please note all date stamps are in a concentrated period of time. I choose LOVE over HATE. Thank you kindly.

According to Millsaps, the frame shop's Google rating plummeted due to negative reviews left by Weaver and his followers, and the shop's business declined.

Weaver sued Millsaps for libel, alleging that she had made knowingly false statements about his criminal record, his affiliation with the KKK, and his "terroristic threats to her customers." Millsaps moved to dismiss the complaint …, arguing among other things that her statements were truthful protected speech made without actual malice.

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