Supreme Court of Louisiana

Philip Shelton v. Nancy Pavon

October 18, 2017236 So. 3d 1233

Summary

The court held that statements made in a judicial proceeding qualify as acts in furtherance of petition or free-speech rights under Article 971 only when they are also connected to a public issue. Because the petition challenging the insurance-beneficiary change concerned a private dispute, Dr. Shelton failed to satisfy his initial burden for an anti-SLAPP motion, and Ms. Pavon was entitled to attorney fees and costs. Justice Weimer and Justice Hughes dissented, arguing that the statute plainly protects statements made in judicial proceedings without a separate public-issue requirement; Justice Crichton concurred in the result while emphasizing the extraordinary nature of the remedy.