Neumann v. LilesAnnotate this Case
The issue this case presented for the Oregon Supreme Court's review centered on whether a defamatory statement made in an online business review was entitled to First Amendment protection. Plaintiff Carol Neumann owned plaintiff Dancing Deer Mountain, LLC, a business that arranged and performed wedding events at a property owned by Neumann. Defendant Christopher Liles was a wedding guest who attended a wedding and reception held on Neumann’s property in June 2010. Two days after those events, Liles posted a negative review about Neumann and her business on Google Reviews, a publicly accessible website where individuals may post comments about services or products they have received. In response to Neumann and Dancing Deer Mountain's defamation claim, Liles filed a special motion to strike under Oregon’s Anti-Strategic Lawsuits Against Public Participation (Anti-SLAPP) statute. After a hearing, the trial court allowed Liles’s motion to strike and entered a judgment of dismissal of Neumann’s defamation claim without prejudice. The Court of Appeals reversed the judgment, reasoning that “the evidence submitted by plaintiffs, if credited, would permit a reasonable factfinder to rule in Neumann’s favor on the defamation claim, and the evidence submitted by [Liles] does not defeat Neumann’s claim as a matter of law.” After its review, the Supreme Court concluded that the online review at issue in this case was entitled to First Amendment protection. The Court therefore reversed the decision of the Court of Appeals to the contrary and remanded the case to the Court of Appeals to resolve a disputed attorney fee issue.