Dziubla v. Piazza
Annotate this CasePlaintiffs-appellants Robert Dziubla and Linda Stanwood claimed defendant Ignatius Piazza II, owner of a Nevada firearms training facility, harassed and threatened them by publishing defamatory statements along with their personal identifying information, and sending associates to invade their home. Piazza retorted that plaintiffs conned him out of thousands of dollars and are now attempting to steal his property and "chill his constitutional rights." The trial court granted in part and denied in part Piazza’s special motion to strike under California’s anti-SLAPP statute. With one important clarification as to the scope of protected activity, the Court of Appeal reached the same conclusion. That clarification involved so-called “doxing” allegations in the complaint: plaintiffs’ claim that Piazza published private personal identifying information about them to thousands of gun enthusiasts as a thinly-veiled threat about what could happen if they continued to litigate the business dispute. Although it was included in an otherwise-protected litigation “alert” that discussed the pending lawsuit, the doxing information was entirely extraneous to the court proceedings that were the ostensible subject of the communication. The Court of Appeal thus rejected Piazza’s assertion that plaintiffs could not meet the “minimal merit” standard on the anti-SLAPP motion because the doxing allegations would necessarily be barred by the litigation privilege in Civil Code section 47(b). The order granting the special motion to strike was reversed in part as to two of plaintiffs’ cause of action ‒ the tenth, seeking an injunction, and the twelfth, alleging a civil rights violation ‒ but only as to the claims included in these causes of action that alleged injury from the publication of their personal information, i.e., the doxing allegations. In all other respects, the order was affirmed. The matter was remanded to the trial court for further proceedings.
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