Participated in an amicus brief (with the Reporters Committee and other amici) filed with the Court of Appeal of the State of California in Smith v. Palisades News. The case involved a defamation suit against the Palisades News brought by an activist who objected to the newspaper’s coverage of her statements on a matter of public interest. The brief argued that the court should find the respondent to be a limited-purpose public figure; that the neutral reportage doctrine applied to the newspaper article in question; and that the wire service defense applied to the article as well. The brief urged the court to grant Palisades News’s anti-SLAPP motion in its entirety. [2019]