Adelson v. HarrisAnnotate this Case
The Supreme Court accepted two questions of law certified to it by the United States Court of Appeals, answering (1) a hyperlink to source material about a judicial proceeding may suffice as a report within the common law fair report privilege; and (2) Delucchi v. Singer, 396 P.3d 826, 830 (Nev. 2017), explains that application of Nevada’s anti-SLAPP statute, prior to the most recent amendments in 2013, is not limited to communication addressed to a government agency but includes speech “aimed at procuring any governmental or electoral action.”
Plaintiff in this case filed a defamation action against Respondents, who posted an online petition to pressure presidential candidate Mitt Romney to reject Appellant’s campaign contributions, alleging that the petition was false and defamatory. The federal district court concluded that Nevada law governed the controversy and dismissed Appellant’s complaint, ruling that the state’s anti-SLAPP statutes applied. On appeal, the court of appeals certified two questions of law to the Supreme Court. The Supreme Court answered the questions and held (1) the fair report privilege immunizes Respondents from civil liability; and (2) communications with either the government or the public that are intended to influence an electoral result potentially fall under Nev. Rev. Stat. 41.637(1).