Glorioso v. Sun-Times Media Holdings, LLC

Summary

The Illinois Supreme Court held that defendants’ newspaper articles were not acts in furtherance of government participation under the Citizen Participation Act and therefore did not support dismissal of the defamation and related claims as a SLAPP. The court adopted an objective standard under which the defendant’s acts must be reasonably calculated to elicit favorable governmental action or an outcome, and concluded that these articles merely reported on a third-party investigation without requesting governmental or electoral action. The court affirmed the appellate judgment and remanded for further proceedings.