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Fridman v. Orbis Business Intelligence Ltd.

District of Columbia Court of Appeals
229 A.3d 494 (2020)

Written by Nathan Benedict, JD

Facts

Orbis Business Intelligence Limited (Orbis) (defendant) conducted opposition research on Donald Trump during the 2016 presidential election campaign. Orbis compiled 17 company intelligence reports (CIRs), some of which documented connections between Trump and Russia. CIR 112 described a relationship between Alfa Group, a Russian business, and Russian President Vladimir Putin, including allegations of bribery and blackmail. Mikhail Fridman, Petr Aven, and German Khan (plaintiffs) (the owners) owned Alfa Group and were mentioned by name in the report. Prior to the publication of CIR 112, other news articles had covered the relationship between the owners and Putin, and the owners had given interviews espousing their views about their involvement with the Russian government. The owners sued Orbis for defamation. Orbis moved to dismiss under the District of Columbia Anti-SLAPP Act. The trial court found that the Anti-SLAPP Act applied because CIR 112 discussed matters of public interest and because the owners were limited-purpose public figures. As public figures, the owners needed to demonstrate actual malice to prevail on a defamation claim, which they had failed to do. The District of Columbia Superior Court dismissed the suit. The owners appealed.

Rule of Law

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Issue

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Holding and Reasoning (Fisher, J.)

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