Flaa v. Hollywood Foreign Press Association
United States Court of Appeals for the Ninth Circuit
55 F. 4th 680

- Written by Sean Carroll, JD
Facts
Kjersti Flaa (plaintiff) was a successful entertainment journalist who sought admission to the Hollywood Foreign Press Association (HFPA) (defendant). The HFPA denied Flaa’s application for membership in 2018, 2019, and 2020. The HFPA had only 85 members and strictly limited admission of new members. HFPA membership enabled member journalists to get unique and exclusive interview access, among other benefits. Flaa asserted that any high-profile non-HFPA interviews had recently begun going to bloggers and social-media influencers rather than traditional journalists. Flaa claimed that HFPA’s membership policies amounted to a group boycott of non-members because the HFPA excluded qualified applicants who might have otherwise competed with HFPA members. For analysis purposes, Flaa asserted a relevant market of foreign journalists reporting on American entertainment. The district court dismissed Flaa’s complaint for failure to state a claim. Flaa appealed.
Rule of Law
Issue
Holding and Reasoning (Miller, J.)
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