Tag Archives: Erie

Atlantic Magazine Responds to Defamation Suit With Anti-SLAPP Motion

The Atlantic Monthly Group and a correspondent have filed an anti-SLAPP/Rule12(b)(6) motion in DC federal court in response to a Complaint by George Boley.  The pro se Complaint, filed January 22, 2013, alleges that statements in a January 2010 article and February 2010 follow-up post on the Atlantic website defamed him by stating that he was a warlord in his native Liberia.  It seeks compensatory and punitive damages.  The defendants’ brief in support of their anti-SLAPP and Rule 12(b)(6) motions first chronicles Boley’s tenure as leader of the Liberian Peace Council, citing to and quoting from a U.S. State Department …

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Will Farah v. Esquire Appeal Resolve “Erie” Question?

While the Sherrod v. Breitbart appeal has attracted a lot of attention at the DC Circuit, there is another case that could resolve whether the DC anti-SLAPP statute applies in federal court: Farah v. Esquire.  There, the plaintiffs/appellants are appealing the district court’s decision granting the defendants’ anti-SLAPP and 12(b)(6) motions and dismissing their false light, defamation, and Lanham Act causes of action. As alleged in the Complaint, a May 2011 post on Esquire’s politics blog contained fictional statements by publisher Joseph Farah that he would destroy the first-run print of Jerome Corsi’s book, Where’s the Birth Certificate? The Case …

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Sherrod v. Breitbart Appeal Ready for Oral Argument

The Sherrod v. Brietbart appeal is now fully briefed (opening brief here, opposition brief here, and reply brief here) and ready for the oral argument, scheduled for March 15, 2013.  (The case has also attracted amicus briefs, including from the District of Columbia, the ACLU and Public Citizen, and a host of news organizations).  The threshold question in Sherrod is whether the denial of an anti-SLAPP motion is immediately appealable under the collateral order doctrine of Cohen v. Beneficial Loan Corp.  (The DC Court of Appeals recently held that it was not).  Under Cohen, the appellants must show that the …

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Roundup on Pending Cases Involving the DC anti-SLAPP Statute

After a period of relative quiet, there has been a flurry of activity in the District of Columbia federal and state courts in cases involving the DC anti-SLAPP statute.  Here’s a summary of where the various cases stand:              •           Sherrod v. Breitbart:  The case drawing the most attention is the pending appeal in the United States Court of Appeals for the District of Columbia Circuit in Sherrod v. Breitbart.  There, the defendants/appellants have filed their opening brief; the District of Columbia has filed an amicus brief; Public Citizen and the American Civil Liberties Union of the Nation’s Capital have filed …

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Another judge to decide if anti-SLAPP statute applies in federal court

In response to a libel complaint filed by Yasser Abbas, one of the sons of Mahmoud Abbas, the Palestinian President, the defendants have filed an anti-SLAPP motion and a separate motion to dismiss the complaint for failure to state a claim.  (The law firm representing Schanzer is the same one that filed an anti-SLAPP motion on behalf of the City Paper in response to the suit brought by Dan Snyder.  Snyder ultimately dismissed his suit before the court ruled on the anti-SLAPP motion). 

DC federal court reiterates that anti-SLAPP statute inapplicable in federal court

While 3M and Lanny Davis were resolving their claims, the judge presiding over the district court portion of the case resurrected his February 2012 decision against another one of the defendants in that same case and held – again – that the DC anti-SLAPP statute does not apply in federal court.  

Lanny Davis Drops High-Profile Appeal of Denial of Anti-SLAPP Motion

With apologies to Queen, another anti-SLAPP suit has bitten the dust.  Unlike the Lehan v. Fox Television Stations case, in which the defendants’ anti-SLAPP motion was granted, however, the high-profile squabble between 3M and Lanny Davis has ended because of a settlement. 

Breitbart Defendants File Opening Brief in DC Circuit

The defendants in the Sherrod v. Breitbart case have filed their opening brief in the DC Circuit.  As you may recall, Judge Leon’s Statement of Reasons, explaining why he denied the anti-SLAPP motion in his minute Order, stated that it was denied because: (a) the lawsuit was filed six weeks before the statute became effective and there was no indication that it was intended to apply retroactively; (b) the statute is inapplicable in federal court, which is required to apply federal procedural law under Erie; and (c) the motion was not timely made. Almost ½ of the appellate brief is …

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Nevada SLAPP Decision Could Impact DC Cases

A decision by the Ninth Circuit Court of Appeals earlier this week could impact three cases currently on appeal to the DC Circuit involving the DC anti-SLAPP statute.  In Metabolic Research, Inc. v. Ferrell, et al., an attorney (Mr. Ferrell) sent a pre-suit letter to Metabolic Research and others which they interpreted as extortion or blackmail.  They responded by filing a suit against Mr. Ferrell and his clients for extortion and related torts.  In turn, Mr. Ferrell filed a special motion to dismiss under Nevada’s anti-SLAPP statute.  The federal district court denied the anti-SLAPP motion, and Mr. Ferrell appealed to the …

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Federal Court Grants Anti-SLAPP Motion in Farah v. Esquire Case

Judge Collyer today became the first federal court judge to grant an anti-SLAPP motion in federal court. Previously, Judge Leon denied an anti-SLAPP motion filed in Sherrod v. Breitbart and Judge Wilkins denied an anti-SLAPP motion filed in 3M v. Boulter. (Of course, Judge King of the DC Superior Court granted an anti-SLAPP motion in Lehan v. Fox). The Farah opinion explains that the anti-SLAPP statute “‘incorporates substantive rights with regard to a defendant’s ability to fend off lawsuits filed by one side of a political or public policy debate aimed to punish the opponent or prevent the expression of …

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