Blockowicz v. Williams, No. 10-1167, (7th Cir. December 27, 2010)
Plaintiffs got an injunction that ordered defendants to remove defamatory content from the web that defendants had posted. When the defendants did not comply with the injunction, plaintiffs asked the court to enforce the injunction against Ripoffreport.com, the website on which some of the defamatory content appeared.
The lower court refused to extend the injunction to cover Ripoffreport. Plaintiffs sought review with the Seventh Circuit. On appeal, the court affirmed the refusal to enforce the injunction.
It held that plaintiffs had failed to show that Ripoffreport was in active concert or participation with the defendants. Absent this collaboration, the website was outside the court’s ability to control.