slapp motion (Connecticut) · Go Syfert
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slapp motion in Connecticut

5 Connecticut opinions name it 2 courts 2023–2025 5 in the last five years

The cases below were cited by Connecticut courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Mindys Cosmetics, Inc. v. Dakargreen
ca9 · 2010 · cited in 2 Connecticut opinions naming this issue, 2024–2025
2 sentences

2025Page 40 CONNECTICUT LAW JOURNAL 0, 0 42 ,0 0 Conn. App. 1 Aguilar v. Eick Elder v. Kauffman, supra, 204 Conn. App. 825 (‘‘[p]roof of probable cause is not as demanding as proof by a preponderance of the evidence’’); People’s United Bank v. Kudej, 134 Conn. App. 432, 442 , 39 A.3d 1139 (2012) (noting ‘‘the very low burden of proof required in a probable cause hearing’’); cf. Mindys Cosmetics, Inc. v. Dakar, 611 F.3d 590, 598 (9th Cir. 2010) (‘‘the second step of the anti-SLAPP inquiry is often called the ‘mini- mal merit’ prong’’); Priore v. Haig, supra, 344 Conn. 670 (D’Auria, J., concurring)

2024See Elder v. Kauffman, supra, 204 Conn. App. 825 ; People’s United Bank v. Kudej, supra, 134 Conn. App. 442 ; see also Mindys Cosmetics, Inc. v. Dakar, 611 F.3d 590, 598 (9th Cir. 2010) (‘‘the second step of the anti- SLAPP inquiry is often called the ‘minimal merit’ prong’’); cf. Priore v. Haig, supra, 344 Conn. 670 (D’Auria, J., concurring) (‘‘the special motion to dis- miss permitted under § 52-196a is easily defeated under a probable cause standard’’).

22
Julie Hersh v. John Tatum and Mary Ann Tatumgreen
tex · 2017 · cited in 2 Connecticut opinions naming this issue, 2023–2023
2 sentences

2023See Spirtos v. Yemenidjian, 137 Nev. 711 , 714, 499 P.3d 611 (2021) (concluding, under similarly worded statute, that ‘‘[the defendant’s] denial that he made the alleged statement [was] irrelevant to step one of the anti-SLAPP analysis’’ (emphasis omitted)); Hersh v. Tatum, 526 S.W.3d 462, 467 (Tex. 2017) (dismissal under Texas’ anti-SLAPP statute was not precluded by fact that defendant denied making statements at issue because ‘‘[t]he basis of a legal action is not determined by the defendant’s admis- sions or denials but by the plaintiff’s allegations,’’ and, ‘‘[w]hen it is clear from the p

2023See Spirtos v. Yemenidjian, 137 Nev. 711 , 714, 499 P.3d 611 (2021) (concluding, under similarly worded statute, that ‘‘[the defendant’s] denial that he made the alleged statement [was] irrelevant to step one of the anti-SLAPP analysis’’ (emphasis omitted)); Hersh v. Tatum, 526 S.W.3d 462, 467 (Tex. 2017) (dismissal under Texas’ anti-SLAPP statute was not precluded by fact that defendant denied making statements at issue because ‘‘[t]he basis of a legal action is not determined by the defendant’s admis- sions or denials but by the plaintiff’s allegations,’’ and, ‘‘[w]hen it is clear from the p

22
SPIRTOS v. YEMENIDJIANgreen
nev · 2021 · cited in 2 Connecticut opinions naming this issue, 2023–2023
2 sentences

2023See Spirtos v. Yemenidjian, 137 Nev. 711 , 714, 499 P.3d 611 (2021) (concluding, under similarly worded statute, that ‘‘[the defendant’s] denial that he made the alleged statement [was] irrelevant to step one of the anti-SLAPP analysis’’ (emphasis omitted)); Hersh v. Tatum, 526 S.W.3d 462, 467 (Tex. 2017) (dismissal under Texas’ anti-SLAPP statute was not precluded by fact that defendant denied making statements at issue because ‘‘[t]he basis of a legal action is not determined by the defendant’s admis- sions or denials but by the plaintiff’s allegations,’’ and, ‘‘[w]hen it is clear from the p

2023See Spirtos v. Yemenidjian, 137 Nev. 711 , 714, 499 P.3d 611 (2021) (concluding, under similarly worded statute, that ‘‘[the defendant’s] denial that he made the alleged statement [was] irrelevant to step one of the anti-SLAPP analysis’’ (emphasis omitted)); Hersh v. Tatum, 526 S.W.3d 462, 467 (Tex. 2017) (dismissal under Texas’ anti-SLAPP statute was not precluded by fact that defendant denied making statements at issue because ‘‘[t]he basis of a legal action is not determined by the defendant’s admis- sions or denials but by the plaintiff’s allegations,’’ and, ‘‘[w]hen it is clear from the p

22
Navellier v. Slettengreen
cal · 2002 · cited in 1 Connecticut opinions naming this issue, 2025–2025
2 sentences

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

11
Godin v. Schencksgreen
ca1 · 2010 · cited in 1 Connecticut opinions naming this issue, 2025–2025
1 sentence

2025D., supra, 229 Conn. App. 345–47 (concluding that § 52-196a ‘‘does not . . . violate the plaintiffs’ con- stitutional right to a jury trial’’ under Connecticut constitution because it ‘‘does not require fact-finding by the court’’); see also Godin v. Schencks, 629 F.3d 79 , 90 n.18 (1st Cir. 2010) (observing that ‘‘[t]here may be a concern’’ that Maine anti-SLAPP statute violates seventh amendment right to trial by jury to extent that it allows ‘‘a judge to resolve a disputed material issue of fact’’ in acting on anti-SLAPP motion); Thurlow v. Nelson, supra, 263 A.3d 501 (noting that ‘‘[m]any

11
Leiendecker v. Asian Women United of Minnesotagreen
minn · 2017 · cited in 1 Connecticut opinions naming this issue, 2025–2025
1 sentence

2025D., supra, 229 Conn. App. 345–47 (concluding that § 52-196a ‘‘does not . . . violate the plaintiffs’ con- stitutional right to a jury trial’’ under Connecticut constitution because it ‘‘does not require fact-finding by the court’’); see also Godin v. Schencks, 629 F.3d 79 , 90 n.18 (1st Cir. 2010) (observing that ‘‘[t]here may be a concern’’ that Maine anti-SLAPP statute violates seventh amendment right to trial by jury to extent that it allows ‘‘a judge to resolve a disputed material issue of fact’’ in acting on anti-SLAPP motion); Thurlow v. Nelson, supra, 263 A.3d 501 (noting that ‘‘[m]any

11
Dr. Jesse Smith, M.D. v. Crestview NuV, LLC, on Its Own Behalf and Derivatively on Behalf of NuVivo Bioscience Solutions, LLC.green
texapp · 2018 · cited in 1 Connecticut opinions naming this issue, 2025–2025
1 sentence

2025Notably, courts in several jurisdictions have described the hearing required under their anti-SLAPP statutes as ‘‘a nonevidentiary hearing.’’ Jogan Health, LLC v. Scripps Media, Inc., 565 P.3d 1160 , 1166 (Colo. App. 2025); see, e.g., id. (‘‘[t]he [trial] court held a noneviden- tiary hearing; reviewed the parties’ briefs, documentary evidence, and affidavits; and granted the [defendants’] special motion to dismiss’’); Emory University v. Metro Atlanta Task Force for the Homeless, Inc., 320 Ga. App. 442, 442 , 740 S.E.2d 219 (2013) (‘‘[a]fter a nonevidentiary hearing, the trial court denied th

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (15)

CaseCitedYears
Opinion of the Justices green
nh · 1994
2 sentences

2025D., supra, 229 Conn. App. 345–47 (concluding that § 52-196a ‘‘does not . . . violate the plaintiffs’ con- stitutional right to a jury trial’’ under Connecticut constitution because it ‘‘does not require fact-finding by the court’’); see also Godin v. Schencks, 629 F.3d 79 , 90 n.18 (1st Cir. 2010) (observing that ‘‘[t]here may be a concern’’ that Maine anti-SLAPP statute violates seventh amendment right to trial by jury to extent that it allows ‘‘a judge to resolve a disputed material issue of fact’’ in acting on anti-SLAPP motion); Thurlow v. Nelson, supra, 263 A.3d 501 (noting that ‘‘[m]any

2025D., supra, 229 Conn. App. 345–47 (concluding that § 52-196a ‘‘does not . . . violate the plaintiffs’ con- stitutional right to a jury trial’’ under Connecticut constitution because it ‘‘does not require fact-finding by the court’’); see also Godin v. Schencks, 629 F.3d 79 , 90 n.18 (1st Cir. 2010) (observing that ‘‘[t]here may be a concern’’ that Maine anti-SLAPP statute violates seventh amendment right to trial by jury to extent that it allows ‘‘a judge to resolve a disputed material issue of fact’’ in acting on anti-SLAPP motion); Thurlow v. Nelson, supra, 263 A.3d 501 (noting that ‘‘[m]any

12025–2025
Fox Searchlight Pictures, Inc. v. Paladino green
calctapp · 2001
2 sentences

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

12025–2025
Freeman v. Schack green
calctapp · 2007
2 sentences

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

12025–2025
Emory University v. Metro Atlanta Task Force for Homeless, Inc. green
gactapp · 2013
2 sentences

2025Notably, courts in several jurisdictions have described the hearing required under their anti-SLAPP statutes as ‘‘a nonevidentiary hearing.’’ Jogan Health, LLC v. Scripps Media, Inc., 565 P.3d 1160 , 1166 (Colo. App. 2025); see, e.g., id. (‘‘[t]he [trial] court held a noneviden- tiary hearing; reviewed the parties’ briefs, documentary evidence, and affidavits; and granted the [defendants’] special motion to dismiss’’); Emory University v. Metro Atlanta Task Force for the Homeless, Inc., 320 Ga. App. 442, 442 , 740 S.E.2d 219 (2013) (‘‘[a]fter a nonevidentiary hearing, the trial court denied th

2025Notably, courts in several jurisdictions have described the hearing required under their anti-SLAPP statutes as ‘‘a nonevidentiary hearing.’’ Jogan Health, LLC v. Scripps Media, Inc., 565 P.3d 1160 , 1166 (Colo. App. 2025); see, e.g., id. (‘‘[t]he [trial] court held a noneviden- tiary hearing; reviewed the parties’ briefs, documentary evidence, and affidavits; and granted the [defendants’] special motion to dismiss’’); Emory University v. Metro Atlanta Task Force for the Homeless, Inc., 320 Ga. App. 442, 442 , 740 S.E.2d 219 (2013) (‘‘[a]fter a nonevidentiary hearing, the trial court denied th

12025–2025
Davis v. Cox green
wash · 2015
2 sentences

2025D., supra, 229 Conn. App. 345–47 (concluding that § 52-196a ‘‘does not . . . violate the plaintiffs’ con- stitutional right to a jury trial’’ under Connecticut constitution because it ‘‘does not require fact-finding by the court’’); see also Godin v. Schencks, 629 F.3d 79 , 90 n.18 (1st Cir. 2010) (observing that ‘‘[t]here may be a concern’’ that Maine anti-SLAPP statute violates seventh amendment right to trial by jury to extent that it allows ‘‘a judge to resolve a disputed material issue of fact’’ in acting on anti-SLAPP motion); Thurlow v. Nelson, supra, 263 A.3d 501 (noting that ‘‘[m]any

2025D., supra, 229 Conn. App. 345–47 (concluding that § 52-196a ‘‘does not . . . violate the plaintiffs’ con- stitutional right to a jury trial’’ under Connecticut constitution because it ‘‘does not require fact-finding by the court’’); see also Godin v. Schencks, 629 F.3d 79 , 90 n.18 (1st Cir. 2010) (observing that ‘‘[t]here may be a concern’’ that Maine anti-SLAPP statute violates seventh amendment right to trial by jury to extent that it allows ‘‘a judge to resolve a disputed material issue of fact’’ in acting on anti-SLAPP motion); Thurlow v. Nelson, supra, 263 A.3d 501 (noting that ‘‘[m]any

12025–2025
All One God Faith, Inc. v. Organic & Sustainable Industry Standards, Inc. green
calctapp · 2010
2 sentences

2025D., supra, 229 Conn. App. 346 (‘‘a court considering a special motion to dismiss does not need to make factual find- ings’’ (internal quotation marks omitted)); Mulvihill v. Spinnato, supra, 228 Conn. App. 794–95 (explaining that ‘‘courts reviewing [special motions to dismiss] are obligated to construe the pleadings, affidavits, and other proof submitted in the light most favorable to the non- moving party’’; they do not weigh evidence or resolve conflicting factual claims in ruling on anti-SLAPP motion to dismiss); Soukup v. Law Offices of Herbert Hafif, 39 Cal. 4th 260, 291 , 139 P.3d 30 , 4

2025D., supra, 229 Conn. App. 346 (‘‘a court considering a special motion to dismiss does not need to make factual find- ings’’ (internal quotation marks omitted)); Mulvihill v. Spinnato, supra, 228 Conn. App. 794–95 (explaining that ‘‘courts reviewing [special motions to dismiss] are obligated to construe the pleadings, affidavits, and other proof submitted in the light most favorable to the non- moving party’’; they do not weigh evidence or resolve conflicting factual claims in ruling on anti-SLAPP motion to dismiss); Soukup v. Law Offices of Herbert Hafif, 39 Cal. 4th 260, 291 , 139 P.3d 30 , 4

12025–2025
People's United Bank v. Kudej green
connappct · 2012
2 sentences

2025Page 40 CONNECTICUT LAW JOURNAL 0, 0 42 ,0 0 Conn. App. 1 Aguilar v. Eick Elder v. Kauffman, supra, 204 Conn. App. 825 (‘‘[p]roof of probable cause is not as demanding as proof by a preponderance of the evidence’’); People’s United Bank v. Kudej, 134 Conn. App. 432, 442 , 39 A.3d 1139 (2012) (noting ‘‘the very low burden of proof required in a probable cause hearing’’); cf. Mindys Cosmetics, Inc. v. Dakar, 611 F.3d 590, 598 (9th Cir. 2010) (‘‘the second step of the anti-SLAPP inquiry is often called the ‘mini- mal merit’ prong’’); Priore v. Haig, supra, 344 Conn. 670 (D’Auria, J., concurring)

2025Page 40 CONNECTICUT LAW JOURNAL 0, 0 42 ,0 0 Conn. App. 1 Aguilar v. Eick Elder v. Kauffman, supra, 204 Conn. App. 825 (‘‘[p]roof of probable cause is not as demanding as proof by a preponderance of the evidence’’); People’s United Bank v. Kudej, 134 Conn. App. 432, 442 , 39 A.3d 1139 (2012) (noting ‘‘the very low burden of proof required in a probable cause hearing’’); cf. Mindys Cosmetics, Inc. v. Dakar, 611 F.3d 590, 598 (9th Cir. 2010) (‘‘the second step of the anti-SLAPP inquiry is often called the ‘mini- mal merit’ prong’’); Priore v. Haig, supra, 344 Conn. 670 (D’Auria, J., concurring)

12025–2025
Soukup v. Law Offices of Herbert Hafif green
cal · 2006
2 sentences

2025D., supra, 229 Conn. App. 346 (‘‘a court considering a special motion to dismiss does not need to make factual find- ings’’ (internal quotation marks omitted)); Mulvihill v. Spinnato, supra, 228 Conn. App. 794–95 (explaining that ‘‘courts reviewing [special motions to dismiss] are obligated to construe the pleadings, affidavits, and other proof submitted in the light most favorable to the non- moving party’’; they do not weigh evidence or resolve conflicting factual claims in ruling on anti-SLAPP motion to dismiss); Soukup v. Law Offices of Herbert Hafif, 39 Cal. 4th 260, 291 , 139 P.3d 30 , 4

2025D., supra, 229 Conn. App. 346 (‘‘a court considering a special motion to dismiss does not need to make factual find- ings’’ (internal quotation marks omitted)); Mulvihill v. Spinnato, supra, 228 Conn. App. 794–95 (explaining that ‘‘courts reviewing [special motions to dismiss] are obligated to construe the pleadings, affidavits, and other proof submitted in the light most favorable to the non- moving party’’; they do not weigh evidence or resolve conflicting factual claims in ruling on anti-SLAPP motion to dismiss); Soukup v. Law Offices of Herbert Hafif, 39 Cal. 4th 260, 291 , 139 P.3d 30 , 4

12025–2025
Coretronic Corp. v. Cozen O'Connor green
calctapp · 2011
2 sentences

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

12025–2025
City of Costa Mesa v. D'Alessio Investments green
calctapp · 2013
2 sentences

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

12025–2025
Armin v. Riverside Community Hospital green
calctapp · 2016
2 sentences

2025Notably, courts in several jurisdictions have described the hearing required under their anti-SLAPP statutes as ‘‘a nonevidentiary hearing.’’ Jogan Health, LLC v. Scripps Media, Inc., 565 P.3d 1160 , 1166 (Colo. App. 2025); see, e.g., id. (‘‘[t]he [trial] court held a noneviden- tiary hearing; reviewed the parties’ briefs, documentary evidence, and affidavits; and granted the [defendants’] special motion to dismiss’’); Emory University v. Metro Atlanta Task Force for the Homeless, Inc., 320 Ga. App. 442, 442 , 740 S.E.2d 219 (2013) (‘‘[a]fter a nonevidentiary hearing, the trial court denied th

2025Notably, courts in several jurisdictions have described the hearing required under their anti-SLAPP statutes as ‘‘a nonevidentiary hearing.’’ Jogan Health, LLC v. Scripps Media, Inc., 565 P.3d 1160 , 1166 (Colo. App. 2025); see, e.g., id. (‘‘[t]he [trial] court held a noneviden- tiary hearing; reviewed the parties’ briefs, documentary evidence, and affidavits; and granted the [defendants’] special motion to dismiss’’); Emory University v. Metro Atlanta Task Force for the Homeless, Inc., 320 Ga. App. 442, 442 , 740 S.E.2d 219 (2013) (‘‘[a]fter a nonevidentiary hearing, the trial court denied th

12025–2025
Lowes v. Thompson green
orctapp · 2024
1 sentence

2025App. 406, 411 , 546 P.3d 311 (‘‘unchallenged evidence of a waiver of the rights protected by the anti-SLAPP statute can satisfy a plaintiff’s burden to defeat an anti-SLAPP motion once a defendant has satisfied [its] burden at the first step’’), review allowed, 372 Or. 560 , 551 P.3d 398 (2024).

12025–2025
Dillon v. Seattle Deposition Reporters, LLC green
washctapp · 2014
1 sentence

2025Page 26 CONNECTICUT LAW JOURNAL 0, 0 28 ,0 0 Conn. App. 1 Aguilar v. Eick factual conflicts’’); Dillon v. Seattle Deposition Report- ers, LLC, 179 Wn.

12025–2025
Malin v. Singer green
calctapp · 2013
2 sentences

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

2025Freeman v. Schack, 154 Cal. App. 4th 719, 733 , 64 Cal. Rptr. 3d 867 (2007); accord Navellier v. Sletten, 29 Cal. 4th 82, 94 , 52 P.3d 703 , 124 Cal. Rptr. 2d 530 (2002) (courts cannot add proof of validity requirement to first prong of anti-SLAPP analysis and any claimed illegitimacy of defendant’s acts is only rele- vant to second prong); Malin v. Singer, 217 Cal. App. 4th 1283, 1304 , 159 Cal. Rptr. 3d 292 (2013) (defendants’ denial of plaintiff’s allegations irrelevant to first prong and ‘‘is more suited to the second step of an anti-SLAPP motion’’ (internal quotation marks omitted)); Cost

12025–2025
Sweetwater Union High Sch. Dist. v. Gilbane Bldg. Co. green
cal · 2019
2 sentences

2025Cf. Sweetwater Union High School District v. Gilbane Building Co., 6 Cal. 5th 931, 949 , 434 P.3d 1152 , 243 Cal. Rptr. 3d 880 (2019) (to be considered by court in ruling on anti-SLAPP motion, it must be reasonably possible that materials submitted by parties will be ‘‘admissible at trial’’). 0, 0 CONNECTICUT LAW JOURNAL Page 19 0 Conn. App. 1 ,0 21 Aguilar v. Eick (2022) (defendants ‘‘attached a police report’’ in support of special motions to dismiss); Gimpelson v. Hartford Courant Co., LLC, Docket No. CV-XX-XXXXXXX-S, 2022 WL 1585356 , *1 n.2 (Conn. Super.

2025Cf. Sweetwater Union High School District v. Gilbane Building Co., 6 Cal. 5th 931, 949 , 434 P.3d 1152 , 243 Cal. Rptr. 3d 880 (2019) (to be considered by court in ruling on anti-SLAPP motion, it must be reasonably possible that materials submitted by parties will be ‘‘admissible at trial’’). 0, 0 CONNECTICUT LAW JOURNAL Page 19 0 Conn. App. 1 ,0 21 Aguilar v. Eick (2022) (defendants ‘‘attached a police report’’ in support of special motions to dismiss); Gimpelson v. Hartford Courant Co., LLC, Docket No. CV-XX-XXXXXXX-S, 2022 WL 1585356 , *1 n.2 (Conn. Super.

12025–2025

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 52-196a (5) CT § Conn. Gen. Stat. § 53a-61 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 1892 (1997–2026) NV 47 (2009–2026) MA 34 (2002–2026) OR 33 (2013–2026) GA 31 (2004–2026) ME 27 (2003–2025) WA 22 (2013–2025) TX 15 (2014–2024) MN 11 (2010–2017) DC 8 (2014–2024) CO 7 (2025–2026) VT 7 (2007–2025) IL 6 (2011–2023) FL 6 (2019–2026) CT 5 (2023–2025) RI 4 (2004–2016) IN 4 (2011–2025) NY 3 (1998–2024) GU 2 (2021–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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