Participated in an amicus brief (with the Reporters Committee and other amici) filed with the U.S. Court of Appeals for the Second Circuit in La Liberte v. Reid. The brief supports the motion of MSNBC journalist Joy Reid for rehearing or rehearing en banc of the Second Circuit’s decision in this case, which reversed a lower court’s dismissal of a defamation suit by Roslyn La Liberte against Reid. The Second Circuit held that California’s anti-SLAPP law, including its fee-shifting provision, is not applicable in federal court, even when dismissal is granted. The amicus brief notes the split between the Second and Ninth circuits regarding the applicability of California’s anti-SLAPP statute. The brief also argues that the Second Circuit’s public-figure analysis (finding La Liberte a private figure) will have a chilling effect on journalists.