Ratcliff v. The Roman Catholic Archbishop of Los Angeles
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Plaintiffs, seven adults claiming that they were molested by a priest when they were children, filed suit against the Archdiocese, alleging that it was vicariously liable for ratifying the molestation and directly liable for its own negligence in failing to supervise the priest. The Archdiocese moved to strike the operative complaint under the anti-SLAPP law, Code of Civil Procedure, section 425.16.
The Court of Appeal affirmed the trial court's denial of the Archdiocese's anti-SLAPP motion, concluding that the gravamen of the suit against the Archdiocese is not speech – it is the molestation and failure to supervise. The court concluded that the Archdiocese mischaracterizes the complaint by arguing that it has established that the child sexual abuse cause of action arises from protected activity because it is based on the Archdiocese's conduct in the Roe litigation and sheriff’s investigation. The court explained that, because the Archdiocese chooses to ignore the bulk of the allegations of the complaint against it, it makes no attempt to argue that these actual allegations are protected activity under the anti-SLAPP law. The court further explained that the focus must be on the alleged acts of sexual abuse and battery that form the basis of the tort cause of action, not the acts of the Archdiocese by which it is alleged to be vicariously liable for those acts. The court concluded that those underlying tortious acts are not protected activity. The court also concluded that a similar analysis defeats the Archdiocese's argument that the negligence cause of action is based on protected speech. Finally, the court concluded that the ruling on demurrer is not before it, and the ruling on the demurrer did not affect, and could not have affected, the order denying the anti-SLAPP motion.
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