https://www.hollywoodreporter.com/thr-esq/msnbc-host-joy-reid-faces-revived-libel-claim-big-appellate-decision-1303284

(http://www.autoadmit.com/thread.php?thread_id=4585555&forum_id=2#40612345)

Before: KEARSE, JACOBS, CABRANES, Circuit Judges.

Roslyn La Liberte appeals from the September 30, 2019 judgment of the United States District Court for the Eastern District of New York (Irizarry, Ch. J.), which both dismissed her defamation claim against Joy Reid under Rule 12(b)(6) and “struck” the claim under California’s Anti-Strategic Lawsuits Against Public Participation (anti-SLAPP) statute. We VACATE that judgment and REMAND the case for further proceedings consistent with this opinion.

We hold (for the first time) that California’s anti-SLAPP statute is inapplicable in federal court because it conflicts with Federal Rules of Civil Procedure 12 and 56. We also vacate the dismissal of the defamation claim under Rule 12(b)(6). As to one of the statements at issue, the court erroneously deemed La Liberte to be a limited purpose public figure (and accordingly dismissed for failure to plead actual malice); as to the other, the court mischaracterized it as nonactionable opinion. We affirm the district court’s conclusion that Reid does not qualify for immunity under section 230 of the Communications Decency Act.

(http://www.autoadmit.com/thread.php?thread_id=4585555&forum_id=2#40612366)