The Michigan Court of Appeals has ruled (PDF) unanimously in favor of a former law student who used his blog to anonymously complain about his former law school, Thomas M. Cooley Law School, based in Lansing.

Doe 1’s counsel, the famed freedom of speech lawyer Paul Levy, of Public Citizen, wrote in a statement on Friday that the decision was a “mixed blessing for anonymous Internet speakers in future cases.”

The defendant, known only as “Doe 1,” who also went by the nom de blog Rockstar05, published a blog called “Thomas M. Cooley Law School Scam,” between February 2011 and May 2012, in which he lambasted his former place of study.

“The assertion by Thomas M. Cooley of its status as the second best law school in America is as ludicrous as asserting that I am the second smartest man in America,” Rockstar05 wrote in 2011. “It would invite the type of backlash that Cooley experiences everywhere throughout the nation. Yet I would not go out and sue someone who has a different opinion, or in the extreme scenario, publicly lambasts me for my declaration and calls me the dumbest man in America.”

Cooley filed a legal complaint against Doe 1 on July 14, 2011, alleging that he made “defamatory accusations” against the school. By August, the appellant (Cooley) subpoenaed Weebly (Doe 1’s blog host)—and Doe 1 moved to quash the disclosure of his identity. A Weebly employee later disclosed it anyway, and the law school filed a new complaint that named him directly. Because Cooley had already discovered Doe 1’s identify, it asked that he remove his motion to quash, which was declined.

The trial court eventually ruled in Cooley’s favor, arguing that “per se slanderous statements are not entitled to First Amendment protection, and thus Cooley would not have to prove actual malice.” That would allow Cooley to use the information it discovered pending Doe 1’s appeal to the appeals court.

The appeals court now allows for Doe 1 to move to dismiss the original complaint. Levy went on to say that he applauded the court's decision to issue protective orders in favor of anonymous speech online, but he had some disagreements with the court's reasoning.

“Also troublesome is the majority’s refusal to address the requirement, adopted by every other state appellate court to address the topic, that the plaintiff suing a Doe defendant give notice of the suit before anonymity can be taken away," Levy added in the statement. "Without notice, an anonymous defendant may not know that a subpoena has been issued seeking his identifying information. Here, the law school critic learned of the lawsuit only because Cooley Law School issued a press release announcing it, which enabled Doe to go to court to block the subpoena.”