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An out-of-state defendant has failed to persuade a California appellate court that he shouldn't be hauled into the state's courts to face claims that he sent anonymous social media messages and fabricated direct messages and text conversations in attempts to undermine a distant relative's relationship.

The Fourth District Court of Appeal on Thursday found that California courts had specific personal jurisdiction over Michigan resident Yousef Zehia, who denied making allegedly defamatory statements about Nicholas Nadhir, a California resident who had been arranged to meet Zehia's relative.

Writing for a unanimous three-judge panel, Fourth District Presiding Justice Judith McConnell noted that though Zehia denied using the social media accounts or creating the fake conversations at the heart of the case, the trial court had made findings based on "substantial evidence" that there was a likelihood that Zehia had used social media accounts in the manner described in the complaint. The appellate court, McConnel noted, was bound by the trial court's finding for purposes of the appeal.

"By sending California-focused messages and conversations directly to California residents for the alleged purpose of interfering with the relationship of California residents and causing reputational injury in California, Zehia has 'purposefully "reach[ed] out beyond" [his s]tate and into' California,'" wrote McConnell, citing Walden v. Fiore, a 2014 decision from the U.S. Supreme Court governing when state courts may exercise jurisdiction over nonresident defendants.

Zehia's lawyer, Lee Sherman of Callahan Thompson Sherman & Caudill, was out of the office and unavailable for comment Friday.

The underlying complaint has a distinctly 21st-century feel, and the ruling is sure to be invoked in further social media-heavy disputes that involve parties across state borders. Nadhir initially sued unnamed doe defendants in July 2018 for defamation, violation of the online impersonation law, appropriation of name or likeness, and intentional infliction of emotional distress after a family-arranged introduction at church with Zehia's distant relative, referred to in court filings as S.M.

According to the appellate opinion, S.M. had never met Nadhir and believed Zehia may be familiar with him, and she therefore asked her relative for information about her arranged suitor.

Shortly thereafter, Nadhir reported receiving social media direct messages sent from usernames he did not recognize, including a friend request from one named "[S.M.]does.not.want.this." Another sent from "nick.check.your.dm.request" read: "[S.M.] is finding this whole thing very stressful and as an invasion of privacy, she is not happy and is being pressured by her family. Best thing is to just let this whole thing go and everyone move on. Tell the moms and aunts to just drop the whole thing. She is finding this to be very unnatural."

In the following weeks, Zehia told S.M. he was in social media contact with an anonymous user familiar with Nadhir who warned him that S.M. was "walking into a trap" and that Nadhir viewed her "as a piece of meat." Zehia claimed the anonymous user forwarded him direct message and text conversations with Nadhir where he purportedly made sexually explicit statements about S.M. and derogatory statements about her family. Zehia sent S.M. screenshots of his conversations with the anonymous user and the anonymous users' alleged conversations with Nadhir.

Nadhir denied making the statements and after filing the initial suit against the Doe defendants conducted discovery which he claimed pointed to Zehia's involvement in the creation of the social media accounts at issue and fabricating the disparaging conversations. Nadhir amended his complaint to name Zehia in January 2019.

Zehia lawyers filed a motion to quash claiming their client didn't make any of the defamatory comments or fabricate digital conversations. But they further argued that even had Zehia engaged in the underlying conduct, the harmful online statements about Nadhir weren't made with knowledge he would suffer harm in California.

In Thursday's order, the Fourth District found the alleged conduct in the case involved "private social media messages aimed exclusively at a California audience." The court held that "this conduct formed the necessary connection between Zehia and California to warrant the exercise of specific personal jurisdiction" and that it differed from other cases involving social media posts directed to less specific audiences where courts have not found jurisdiction.

Nadhir's appellate lawyer, Marisa Janine-Page of Caldarelli Hejmanowski Page & Leer, said in a phone interview Friday that she felt like she faced an uphill battle at the Court of Appeal since the court had issued an order to show cause why Zehia's request for relief should not be granted. She said that she was prepared to discuss more than 30 cases involving social media going into oral argument, but that there weren't any cases completely on point going her client's way. But she added that her client's case presented cyber-bullying targeted into the state at Californians, giving the defendant's actions the "quality and nature" requiring him to submit to jurisdiction in California.