Roberts
Roberts v. Los Angeles County Bar Assn.
Opinion
Opinion
Woods, J.
Defendant Los Angeles County Bar Association (Bar Association) appeals from an order denying its special motion to strike under Code of Civil Procedure section 425.16 (the anti-SLAPP [strategic lawsuit against public participation] statute). The court found the anti-SLAPP statute did not apply to plaintiff Vicki M. Roberts’s complaint for breach of contract and fraud. The complaint arose from defendant’s rating of plaintiff as “not qualified” when she ran for judicial office in 2000. We conclude that the statute applies to this action and that plaintiff did not establish a prima facie case. Accordingly, we reverse with directions to enter an order granting the motion.
Factual and Procedural Synopsis
I. The Bar Association’s Rating Process
Through its judicial election evaluations committee (Committee), the Bar Association evaluates all candidates in contested elections for Los Angeles County judgeships and publicly disseminates its evaluations through its website, membership mailings and the media.
The evaluation process is described in the judicial election evaluations committee handbook (Handbook) and the rules of the judicial election evaluations committee…