Barkley

I. INTRODUCTION

Debra Lynn Barkley filed a civil harassment restraining order petition against Zohra Fahim. Fahim filed a special motion to strike the petition under the anti-SLAPP statute,1 which the trial court denied. In employing prong one of the required two-pronged analysis, the trial court determined Barkley’s restraining order petition was based on four categories of acts: aggressive confrontations, trespassing, surveillance, and defamation. The court found the first three were not subject to anti-SLAPP protection and denied the motion as to those three categories. Moving to the second prong for the alleged defamation, the trial court determined Barkley showed a probability of success and therefore denied the motion as to the remaining category of acts. On appeal, Fahim limits her claims of error to the trial court’s prong- two analysis. We therefore affirm the trial court’s partial prong-one denial of the motion, regarding aggressive confrontations, trespassing, and surveillance. As for prong two, we agree that Barkley failed to carry her burden in showing a probability of success regarding harassment by defamation and therefore reverse the trial court’s ruling on that…