From today's opinion by Judge Nancy Freudenthal (D. Wyo.) in McCollum v. Baldwin:
This case arises from opinions expressed by Defendant [Alec] Baldwin through social media posts and private messages concerning Plaintiff Roice McCollum's attendance at the Washington, D.C. events on January 6, 2021. Plaintiffs ("the McCollums") allege Mr. Baldwin's opinions resulted in hateful messages and threats by third parties toward them, and they bring this action alleging various causes of action…. The Court finds and concludes that the McCollums have failed to meet their burden of proof in showing that this Court may properly exercise personal jurisdiction over Mr. Baldwin….
Focusing just on the allegations from the complaint which go toward the personal jurisdiction analysis, on January 3, 2022, Roice McCollum (who resides in Wyoming) posted on her Instagram feed a photograph of people surrounding the Washington Monument at the "Make America Great Again" protest in Washington. Roice McCollum had attended the Washington D.C. protest. Mr. Baldwin (from New York) commented on Roice's post by saying, "Are you the same woman that I sent the $ to for your sister's husband who was killed during the Afghanistan exit." {Jiennah McCollum's husband Rylee died in Afghanistan while on active duty as a marine. A GoFundMe account was started on behalf of Jiennah and her soon-to-be-born daughter.} The private Instagram messages between Mr. Baldwin and Roice McCollum on January 3, 2022 are as follows:
