Part 1: A Landmark Lawsuit Under 15 U.S.C. § 6851 — The Civil Path to Justice for Revenge Porn Victims
In our earlier article, we discussed the Fifth Circuit’s groundbreaking appellate decision in Doe v. Gipson, the first ever to interpret the federal civil revenge porn statute, 15 U.S.C. § 6851. We followed up with an introduction to our five-part series examining this pivotal case in depth.
When Congress enacted the Civil Action Relating to Disclosure of Intimate Images Act in 2022, it created a first-of-its-kind federal civil right: the ability for revenge porn victims to sue in federal court. This law—codified at 15 U.S.C. § 6851 and effective as of October 1, 2022—empowers survivors to seek emergency injunctive relief, monetary damages, and attorney’s fees.
Since then, numerous lawsuits have been filed nationwide. But the case of Jane Doe v. Mark A. Gipson, filed in the U.S. District Court for the Western District of Texas, is historic:
- One of the earliest lawsuits brought under § 6851
- The first known case to proceed to a full jury trial under the statute
- The first case to yield a published federal appellate opinion interpreting the law’s injunctive relief provisions
What Happened in Jane Doe v. Gipson?
Jane Doe alleged that her ex-boyfriend, Mark Gipson, unlawfully distributed sexually explicit images and videos of her online—including via email and anonymous websites. According to the lawsuit, Gipson’s actions were part of a calculated effort to harass and publicly shame her.
Doe filed her lawsuit under seal and under a pseudonym. She also sought an emergency restraining order to stop the continued sharing of her private images. The court initially granted her emergency request and sealed the filings. However, Gipson ignored the court’s order, refused to appear, and was ultimately held in contempt of court.
Why This Case Matters
This case shows that 15 U.S.C. § 6851 is more than symbolic—it is enforceable. Federal courts can:
- Issue emergency relief to protect victims
- Use contempt powers to enforce compliance
- Allow victims to proceed anonymously when necessary
- Assert jurisdiction over online and cross-state abuse
More importantly, Doe v. Gipson confirms that protection from digital sexual abuse is now a federal civil right.
What’s Next in the Series
In Part 2, we will look at how the court granted emergency protections for Jane Doe and enforced those protections through contempt proceedings. You’ll learn why speed matters in online image abuse cases and how this law allows fast action to prevent further harm.
Are You a Victim of Revenge Porn or Sextortion?
Contact our office today to learn about your rights under 15 U.S.C. § 6851. You may be entitled to:
- A federal injunction to stop further harm
- Monetary compensation
- Protection of your identity in court
You don’t have to fight alone. Justice is possible—and it starts with federal law.
