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Makaeff v. Trump University, LLC

United States Court of Appeals for the Ninth Circuit
736 F.3d 1180 (2013)


Tarla Makaeff (plaintiff) was a customer of Trump University, LLC (Trump University) (defendant), which was a for-profit, private entity purporting to teach Donald Trump’s insider success secrets. Makaeff sued Trump University for deceptive business practices. Trump University then counter-claimed against Makaeff for defamation. Makaeff moved to strike the counterclaim under the anti-SLAPP statute, alleging that Trump University was a public figure and would be required to prove actual malice to succeed on a defamation claim. The trial court denied the motion to strike. Makaeff appealed to the United States Court of Appeals for the Ninth Circuit.

Rule of Law


Holding and Reasoning (Wardlaw, J.)

Concurrence (Wardlaw, J)

Concurrence (Kozinski, C.J.)

Dissent (Watford, J.)

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