Overview
- Chief U.S. District Judge Andrew P. Gordon granted the blogger Jim Stewartson’s motion on July 25, dismissing the Nevada case for lack of personal jurisdiction and vacating the prior $250,000 default judgment under Rule 60(b).
- The judge applied the Supreme Court’s Calder v. Jones effects test and the Ninth Circuit minimum-contacts framework and found that tagging a Nevada resident in nationwide posts did not mean the blogger expressly aimed his conduct at Nevada.
- Patel had won a default judgment in August 2025 after Stewartson initially did not defend, and Stewartson moved in September 2025 to set aside the judgment arguing improper service, lack of jurisdiction, and First Amendment protection for his speech.
- Judge Gordon criticized Stewartson’s conduct during the litigation, saying the blogger appeared to know about the suit and may have tried to avoid service, but the judge said a judgment void for lack of jurisdiction could not stand and he lacked discretion to award fees.
- Patel is still pursuing other defamation claims, including a $250 million suit against The Atlantic that the magazine is fighting and that could draw federal records into discovery while raising broader questions about public‑figure libel law and press freedom.