Sebastian D'Elia, director of the Office of Public Information of Union County, New Jersey, filed a lawsuit against two members of The Union County Watchdog Association after they allegedly defamed him in blog posts. Defendants Tina Renna and Patricia Quattrocchi were regular posters to the watchdog group's blog, The County Watchers. According to news reports, D'Elia took issue with a blog post titled "County Hacks are Soulless Pyschopaths," which allegedly compared him to Adolf Hitler.

Both D'Elia and the defendants moved for summary judgment in the case.  After hearing oral argument on the two motions, the court granted summary judgment to the defendants on the ground that D'Elia had not provided sufficient proof of damages. The court reportedly also noted that D'Elia was a public official, which meant he was subject to criticism even if it was "mean-spirited," "unflattering," and "poorly written."