Quest v. Rekieta
Minnesota Court of Appeals
2024 WL 2266941 (2024)
- Written by Jamie Milne, JD
Facts
Colorado resident Steve Quest (plaintiff) sued Minnesota attorney Nicholas Rekieta (defendant), alleging that Rekieta made defamatory statements about Quest online. Quest filed the suit in Minnesota state court. Rekieta moved to dismiss the claim under Colorado’s anti-SLAPP statute, meaning Colorado’s law preventing strategic lawsuits against public participation. Anti-SLAPP statutes were intended to provide a means of quickly dismissing meritless lawsuits filed to silence or punish persons for exercising their free-speech or free-petition rights on matters of public concern. Quest argued that Minnesota law governed, not Colorado law. Minnesota’s anti-SLAPP statute had been previously struck down as unconstitutional because it required district courts to make pretrial factual findings that could result in complete dismissal, usurping the state constitutional right to a jury for civil matters. Applying Minnesota’s five-factor choice-of-law test, the trial court concluded that Minnesota law governed. The court therefore denied Rekieta’s motion to dismiss because Colorado’s anti-SLAPP statute was inapplicable. Rekieta appealed that choice-of-law decision.
Rule of Law
Issue
Holding and Reasoning (Ede, J.)
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