Bonni v. St. Joseph Health System

Summary

The court held that an anti-SLAPP motion directed at a retaliation cause of action must analyze each act or set of acts supplying a basis for relief, rather than the overall gravamen of the cause of action. Statements and reports made in connection with hospital peer review, advocacy during peer review, and related settlement negotiations are protected activity, but the resulting suspension or termination of hospital privileges is not merely because it followed protected communications. The court reversed the Court of Appeal in part and remanded for consideration of whether the claims based on protected activity have minimal merit.