Manufactured Home Communities, Inc. v. County of San Diego

Equity Lifestyle Properties, Inc., formerly known as Manufactured Home Communities, Inc. (“MHC”), appeals the district court’s decision granting the County of San Diego and County Supervisor Dianne Jacob’s (collectively “Defendants”) motion to strike MHC’s defamation suit under California’s anti-SLAPP (Strategic Lawsuit Against Public Participation) statute. See Cal.Civ.Proc.Code § 425.16. MHC argues that the district court erred in concluding that MHC failed to make a prima facie case that various statements made by Jacob were false. MHC also appeals the district court’s order granting attorney’s fees under California’s antiSLAPP statute.

We affirm.

I. Background

MHC is a real estate investment trust based in Chicago. Manufactured Home Cmtys., Inc. v. Cnty. of San Diego (MHC), 544 F.3d 959, 961 (9th Cir.2008). MHC owns and operates mobile home parks throughout the United States. Id. MHC has three parks in unincorporated areas of San Diego County, called Lamplighter Village, Rancho Valley, and Rancho Mesa. Id. This appeal is based on allegedly defamatory statements made by Supervisor Dianne Jacob in response to two events at the parks.

The first event was MHC’s…