Section 52-196a

Citation: Section 52-196a
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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the United States Court of Appeals for the Second Cir-
       cuit recently stated: ‘‘[S]peech on matters of public con-
       cern is at the heart of [f]irst [a]mendment protection.
       . . . Whether speech addresses a matter of public con-
       cern is to be determined by the content, form, and
       context of [the relevant] statement, as revealed by the
       whole record. . . . Speech that relates to any matter
       of political, social, or other concern to the community
       . . . which may include conduct implicat[ing] public
       safety and welfare . . . for example, generally falls
       within the heart of the [f]irst [a]mendment’s protec-
       tion.’’ (Citations omitted; emphasis omitted; internal
       quotation marks omitted.) Rupp v. Buffalo, 91 F.4th
       623, 635 (2d Cir. 2024).
          Moreover, courts in California and Nevada, which
       have similar anti-SLAPP statutes, have utilized the fol-
       lowing principles for distinguishing between a public
       and private interest: ‘‘First, public interest does not
       equate with mere curiosity. . . . Second, a matter of
       public interest should be something of concern to a
       substantial number of people. . . . Thus, a matter of
       concern to the speaker and a relatively small, specific
       audience is not a matter of public interest. . . . Third,
       there should be some degree of closeness between the
       challenged statements and the asserted public interest
       . . . the assertion of a broad and amorphous public
       interest is not sufficient . . . . Fourth, the focus of the
       speaker’s conduct should be the public interest rather
       than a mere effort to gather ammunition for another
       round of [private] controversy. . . . Finally, those
       charged with defamation cannot, by their own conduct,
       create their own defense by making the claimant a
       public figure. . . . A person cannot turn otherwise pri-
       vate information into a matter of public interest simply
       by communicating it to a large number of people.’’ (Cita-
       tions omitted; internal quotation marks omitted.) Wein-
       berg v. Feisel, 110 Cal. App. 4d 1122, 1132, 2 Cal. Rptr.
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