Westbrook v. Paulson

Full title:TATIANA WESTBROOK, an individual; JAMES WESTBROOK, an individual; HALO…

Court: UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE

NO. 2:20-cv-1606

Date published: Mar 15, 2021

Fact:

Plaintiffs Tatiana Westbrook, James Westbrook, and Halo Beauty Partners, LLC (collectively “Plaintiffs”) bring a lawsuit against Defendants Katie Joy Paulson and Without a Crystal Ball, LLC (collectively “Defendants”). Tatiana Westbrook is an internet personality known for critiquing beauty products on social media, and she owns Halo Beauty Partners, a nutraceuticals company. Defendants, based in Minnesota, consist of Paulson, an internet blogger and vlogger, and her company Without a Crystal Ball. Defendants have a substantial online presence, with an estimated 135,000 YouTube followers. Since May 2019, Defendants have uploaded videos targeting the Westbrooks and Halo, allegedly intending to harm their reputation and financial interests. Plaintiffs sue for defamation, intentional infliction of emotional distress, and violations of the Washington Consumer Protection Act, seeking $5 million in damages.

Issue:

  • Whether the Court has personal jurisdiction over Defendants, considering their online activities and connections to Washington.
  • Whether Plaintiffs’ counsel, Michael Saltz, should be sanctioned under 28 U.S.C. § 1927 for alleged misconduct related to the Declaration of Lori Barnhart.

Decision:

  • The Court grants Defendants’ Motion to Dismiss for lack of personal jurisdiction. Although Plaintiffs argue that Defendants’ videos were accessible to Washington residents and caused harm, the Court finds that Defendants’ conduct did not purposefully target Washington. The Court concludes that Washington is an improper forum, and personal jurisdiction is lacking.
  • The Court denies Defendants’ Motion for Sanctions without prejudice. The alleged misconduct by Plaintiffs’ counsel is serious but convoluted, and the Court cannot rule on the motion without an extensive evidentiary hearing. Additionally, since the case is being dismissed, the Court decides not to investigate further, and the Motion for Sanctions is denied without prejudice.

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