La Liberte v. Reid
United States Court of Appeals for the Second Circuit
966 F.3d 79 (2020)
- Written by Jamie Milne, JD
Facts
While attending a city-council meeting in California to oppose California’s sanctuary law, Roslyn La Liberte (plaintiff) engaged in a conversation with a Latino teenager. A photo of the exchange went viral, and someone falsely tweeted that La Liberte had been yelling racial slurs at the teenager. Cable-news commentator Joy Reid (defendant) reposted the photo with commentary expressly stating that La Liberte had used racial slurs. Both La Liberte and the teenager affirmed that no such racial slurs were exchanged and that their conversation was civil in nature. La Liberte sued Reid for defamation in a federal district court in New York, invoking the court’s diversity jurisdiction. The parties agreed that California substantive law governed. Reid moved to dismiss La Liberte’s claim under California’s anti-SLAPP statute, meaning California’s law preventing strategic lawsuits against public participation. The district court granted Reid’s motion, and La Liberte appealed, arguing that California’s anti-SLAPP statute did not apply in federal court.
Rule of Law
Issue
Holding and Reasoning (Jacobs, J.)
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