Gaston Cornu-Labat v. Mehdi Merred

MEMORANDUM

Gaston Cornu-Labat appeals the district court’s summary judgment in favor of Mehdi Merred, police officers Eric Bakke and Thomas Clark, the City of Quincy, and Grant County. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and we affirm.

Cornu-Labat’s claims of outrage, defamation, and false light against Merred fail because Merred is immune from civil liability under Washington’s anti-SLAPP statute, Wash. Rev.Code Ann. (“RCW”) § 4.24.510. Merred’s calls to law enforcement and school employees were “reasonably of concern” to both, for law enforcement to enforce the protection order and for the school to ensure the safety of its students. RCW § 4.24.510; see Bailey v. State, 147 Wash.App. 251 , 191 P.3d 1285, 1287 (2008). Washington law does not require good faith on the part of Merred to receive this statutory protection. See Phoenix Trading, Inc. v. Loops LLC, 732 F.3d 936, 942 (9th Cir.2013) (providing that RCW § 4.24.510 does not include a good faith requirement); Bailey, 191 P.3d at 1290-91 (holding that the good faith reference in the anti-SLAPP statute’s purpose section is trumped by the statute’s more specific provision setting out requirements for receiving…