CoreCivic, Inc. v. Candide Group, LLC

46 F.4th 1136 (2022)

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CoreCivic, Inc. v. Candide Group, LLC

United States Court of Appeals for the Ninth Circuit
46 F.4th 1136 (2022)

Facts

CoreCivic, Inc. (plaintiff) was a private prison company. Journalist Morgan Simon (defendant) published articles heavily criticizing CoreCivic’s role in immigrant detention at the United States border. CoreCivic sued Simon and her company, Candide Group, LLC (Candide) (defendant), for defamation in a federal district court in California, invoking the court’s diversity jurisdiction. Candide filed a special motion to strike the claim under California’s anti-SLAPP statute, meaning California’s law preventing strategic lawsuits against public participation. Anti-SLAPP statutes were intended to provide a quick and cost-effective procedural mechanism for dismissing meritless lawsuits filed to silence or punish persons for exercising their free-speech or free-petition rights. California’s statute required dismissal of a defamation claim unless a court concluded that the plaintiff had established a probability of success. Applying the statute, the district court dismissed CoreCivic’s claim. CoreCivic appealed to the Ninth Circuit, arguing that the anti-SLAPP statute did not apply in federal court because it conflicted with the Federal Rules of Civil Procedure.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

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