Lukasz Gottwald v. Kesha Rose Sebert

Summary

The Court held that Gottwald is a limited-purpose public figure and therefore must prove by clear and convincing evidence that Sebert's allegedly defamatory statements were made with actual malice. It held that five statements made in judicial proceedings are absolutely privileged, while the applicability of the qualified pre-litigation and statutory fair-report privileges to the remaining statements presents factual questions for a jury. The Court further held that the 2020 anti-SLAPP amendments apply to the continued prosecution of this action after their effective date, allowing Sebert to pursue statutory relief based on that post-effective-date continuation.