Robinson v. V. D. (2024)

Citation: Robinson v. V. D. (2024)
Parent Document: Robinson v. V. D. (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-11-26
Original Source: https://www.courtlistener.com/opinion/10282961/robinson-v-v-d/ ↗
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Robinson and Mary Robinson, seeks compensatory
         damages and injunctive relief for defamation, invasion
         of privacy by false light, statutory and common-law
         vexatious litigation, and intentional and negligent inflic-
         tion of emotional distress. The defendant claims that
         (1) the court improperly denied his special motion to
         dismiss the action on the ground that his alleged con-
         duct did not relate to an exercise of a protected right
         in connection with a matter of public concern and, thus,
         fell outside the scope of § 52-196a,3 and, (2) even if he
         is not entitled to a dismissal of the action pursuant to
         § 52-196a, the trial court lacks subject matter jurisdic-
         tion over this action because the defendant is entitled
         to absolute immunity under the litigation privilege for
         his alleged conduct, all of which occurred in the course
         of judicial or quasi-judicial proceedings. In addition to
         of its right of free speech, right to petition the government, or right of
         association under the Constitution of the United States or the Constitution
         of the state in connection with a matter of public concern, unless the party
         that brought the complaint . . . sets forth with particularity the circum-
         stances giving rise to the complaint . . . and demonstrates to the court
         that there is probable cause, considering all valid defenses, that the party
         will prevail on the merits of the complaint . . . .
                                               ***
            ‘‘(h) The provisions of this section shall not . . . (3) affect, limit or pre-
         clude the right of a party filing a special motion to dismiss to any defense,
         remedy, immunity or privilege otherwise authorized by law . . . .’’
            2
              ‘‘SLAPP is an acronym for strategic lawsuit against public participation,
         the distinctive elements of [which] are (1) a civil complaint (2) filed against
         a nongovernment individual (3) because of their communications to govern-
         ment bodies (4) that involves a substantive issue of some public concern.
         . . . The purpose of a SLAPP suit is to punish and intimidate citizens who
         petition state agencies and have the ultimate effect of chilling any such
         action.’’ (Internal quotation marks omitted.) Lafferty v. Jones, 336 Conn.
         332, 337 n.4, 246 A.3d 429 (2020), cert. denied,       U.S.    , 141 S. Ct. 2467,
         209 L. Ed. 2d 529 (2021).
            3
              The Connecticut AFL-CIO filed an amicus curiae brief in support of the
         defendant’s contention that the court improperly denied his special motion
         to dismiss. It argues that protecting public employees against retaliatory
         lawsuits for exercising their right to engage in mandatory union grievance
         procedures is precisely the type of ill that § 52-196a was designed to prevent.
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