Free Speech

Eugene Volokh | 8.6.2025 8:32 AM

From Thursday's decision by N.Y. trial judge Dakota Ramseur in Talbert v. Tynes, rejecting defendants' motion to dismiss:

In his complaint, Talbert alleges that Tynes, an acquaintance and former Ph.D. candidate at Columbia University, made various posts to Twitter in November 2021 concerning their interactions as students that accused him of stalking and of being generally abusive and manipulative towards women. More specifically, Tynes' tweets responded to a photograph shared by third party Derecka Purnell, a prominent scholar and author on Black History, that identified Talbert as being "in the tradition of black liberation theology" and as "legendary James Cone's last student." Tynes reposted the image with the caption, "If I speak, Twitter will suspend me," followed by two tweets: "Not the abolitionist [Purnell] with my stalker," and "That man has harmed multiple women and is abusive and manipulative, but congrats on his dissertation, I guess."

Talbert contends that these statements were false, published with actual malice, and caused reputational, emotional, and professional harm.

In support of her … motion to dismiss, Tynes submitted an affidavit describing the context of her prior interactions with him and the alleged basis for her public tweets. In it, she explains that they both attended Columbia University as graduate students between 2017 and 2020, enrolled in a Spring 2018 seminar titled DuBois@150, and participated in a shared study group.

According to her, during the seminar, Talbert would sit across from her, stare at her, and move physically closer without speaking. On or about April 25, 2018, while walking to class, Talbert allegedly followed her, remarked, "that was one of three creepy ways I thought to approach you," and showed her photos he had taken of her walking. Tynes further alleges that Talbert asked where she lived, whether she lived alone, if anyone would notice if she did not come home, whether she drank or used drugs, and then invited her to become inebriated with him.

Around this time, she disclosed her discomfort with Talbert's conduct to their study group and stated that she did not want to be around him. In response, Talbert accused her of bullying, which prompted her to leave the group. The next semester, at a Fall 2018 Welcome Back Mixer, Tynes avers that Talbert made unwanted sexual advances toward her and, after she rejected them, he conspicuously followed her around the event—behavior that, she alleges, was observed by a Columbia University employee.

Following........

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