California Appellate Tracker

Rand Resources, Inc. v. City of Carson

June 8, 2016

Breach or interference with the City of Carson’s contract with an agent for negotiations for an NFL team to come to the city is not protected speech under the Anti-SLAPP statute.

The trial court improperly dismissed this action under the Anti-SLAPP statute. Here, the owner of property in Carson entered into a contract with the city to act as its exclusive agent in trying to negotiate for an NFL team to move to Carson and build its stadium on the owner’s property. The owner’s complaint alleged that in violation of that contract, during its unexpired term, the city authorized another party to negotiate for an NFL team to move to Carson, and that the other party not only did so but also tried to pawn itself off to NFL teams as the plaintiff, using a similar business name. Though having an NFL team move to Carson was a matter of public interest, breach of or interference with the city’s contract with plaintiff was not protected speech. Nor were the other party’s private communications to NFL teams in which it impersonated plaintiff.

California Court of Appeal, Second District, Division 1 (Lui, J.); May 31, 2016: 2016 WL 3085525

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Rand Resources, Inc. v. City of Carson

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