Part 2: How the Court Protected Jane Doe — Injunctive Relief, Contempt, and the Power of § 6851

In Part 1 of our series on Jane Doe v. Mark A. Gipson, we explored how this groundbreaking federal lawsuit was the first to reach trial under 15 U.S.C. § 6851, the federal revenge porn statute enacted in 2022. This followed our series introduction and coverage of the Fifth Circuit’s appellate opinion interpreting the law’s injunctive relief provisions.

This post—Part 2—focuses on the emergency court actions that protected Jane Doe in the early stages of her case. These events illustrate how 15 U.S.C. § 6851 empowers victims of nonconsensual image abuse to obtain swift and meaningful relief in federal court.

Emergency Protection Through a Federal TRO

After filing her lawsuit under seal and pseudonym, Jane Doe requested a temporary restraining order (TRO) to stop the continued distribution of her intimate images. The court quickly granted the TRO, recognizing the immediate threat posed by the anonymous sharing of explicit media files across various websites and email accounts.

The judge issued the restraining order based on Doe’s sworn declarations and supporting exhibits. Importantly, the court allowed media evidence—including explicit files—to remain sealed and confidential while granting relief. This underscores how § 6851 provides real protections without exposing survivors to further trauma in court.

When Gipson Ignored the Court

Defendant Mark A. Gipson failed to appear at the initial hearing and blatantly violated the court’s order. In response, the judge issued a bench warrant and held him in contempt. U.S. Marshals took him into custody and brought him before the court.

At the contempt hearing, the judge made clear that federal orders are enforceable and non-negotiable. Gipson was temporarily jailed and later released only under strict compliance conditions, a signal that courts are prepared to use every tool at their disposal to enforce § 6851 protections.

This Is What § 6851 Was Meant to Do

15 U.S.C. § 6851 isn’t just about civil damages. It provides powerful procedural tools for stopping revenge porn before it spreads further. Key features of the statute include:

• The right to emergency injunctive relief and restraining orders
• The ability to proceed anonymously using a pseudonym
• The availability of a federal forum, regardless of state boundaries or dollar amount
• The recovery of attorney’s fees and potential punitive damages

Doe’s case demonstrates how quickly these protections can be enforced—and why having a knowledgeable legal team is essential for any victim of online sexual abuse seeking immediate help.

Coming Up in Part 3

In Part 3, we’ll cover the trial itself: how the jury was selected, what evidence was presented, and what the final verdict means for future revenge porn lawsuits under federal law.

Are You Being Threatened or Harmed by Revenge Porn?

If someone is distributing or threatening to share intimate images of you without your consent, you may have rights under 15 U.S.C. § 6851. Contact our firm today to discuss your options. Like Jane Doe, you may be able to file under seal and obtain an emergency restraining order in federal court.

Your privacy, safety, and dignity matter. Legal protection is available—now at the federal level.