Jackson v. Mayweather
217 Cal. Rptr. 3d 234
Cal. Ct. App.2017Background
- Shantel Jackson (public figure) sued Floyd Mayweather for invasion of privacy (public disclosure of private facts and false light), defamation, and intentional/negligent infliction of emotional distress based largely on Mayweather’s social‑media posts and radio comments about Jackson’s pregnancy termination (sonogram and medical summary) and alleged cosmetic surgery.
- Mayweather posted on Facebook/Instagram that Jackson “got an abortion” and published a sonogram and medical summary; he later discussed the matter on a radio interview and commented about her cosmetic surgery. Media republishes followed and Jackson alleged public harassment and threats.
- Mayweather filed an anti‑SLAPP special motion to strike under Cal. Code Civ. Proc. § 425.16, arguing his statements were protected speech on a public issue and that Jackson could not show falsity or actual malice.
- The trial court denied the anti‑SLAPP motion, finding Jackson showed a probability of prevailing on the privacy, false light, and defamation claims.
- The Court of Appeal held the challenged statements were protected activity under § 425.16 because they occurred in public forums and involved matters of public interest (celebrity relationship and abortion), but analyzed each claim separately at the second step for likelihood of success. The court reversed the denial as to defamation and false light and as to the public‑disclosure claim based on the cosmetic‑surgery comments, while affirming denial as to the private‑facts claim based on the sonogram/medical summary and affirming other portions.
Issues
| Issue | Plaintiff's Argument (Jackson) | Defendant's Argument (Mayweather) | Held |
|---|---|---|---|
| Whether the challenged statements arise from protected activity under § 425.16 | Jackson: statements were harassment and not genuinely about public interest | Mayweather: posts/interview concerned public figures and abortion, made in public forums, thus protected | Held: Yes — social‑media posts and radio statements were protected activity tied to a public issue/person in the public eye |
| Whether Jackson showed a probability of prevailing on public disclosure of private facts (sonogram/medical summary) | Jackson: sonogram and medical summary were private, disclosure offensive and not newsworthy | Mayweather: topic of abortion/public breakup is newsworthy | Held: Jackson showed probability of success for the claim based on posting the sonogram and medical summary (not newsworthy disclosure) |
| Whether Jackson showed a probability of prevailing on defamation (statements about abortion and cosmetic surgery) | Jackson: Mayweather falsely blamed her for the breakup and exaggerated surgery, causing reputational harm | Mayweather: breakup‑reason is opinion or true; cosmetic‑surgery comments substantially true; no actual/constitutional malice shown | Held: Reversed denial of anti‑SLAPP as to defamation — plaintiff failed to show probability of prevailing (abortion/breakup statement did not cause reputational injury; surgery exaggeration substantially true) |
| Whether Jackson showed a probability of prevailing on false light portrayal | Jackson: same statements placed her in a false, offensive light | Mayweather: statements are protected or substantially true; not actionable false light | Held: Reversed denial as to false light — failed to meet required showing tied to defamation standards |
Key Cases Cited
- Baral v. Schnitt, 1 Cal.5th 376 (Cal. 2016) (two‑step anti‑SLAPP framework and requirement to show probability of prevailing on each challenged claim)
- Shulman v. Group W Productions, 18 Cal.4th 200 (Cal. 1998) (elements of public disclosure of private facts and newsworthiness defense)
- Taus v. Loftus, 40 Cal.4th 683 (Cal. 2007) (truthful newsworthy disclosures bar private‑facts liability)
- New York Times Co. v. Sullivan, 376 U.S. 254 (U.S. 1964) (actual malice standard for public‑figure defamation)
- Catsouras v. Department of California Highway Patrol, 181 Cal.App.4th 856 (Cal. Ct. App. 2010) (unauthorized publication of graphic private images can support privacy claim despite public‑interest arguments)
- Gertz v. Robert Welch, Inc., 418 U.S. 323 (U.S. 1974) (distinction between all‑purpose and limited public figures; malice requirement for public figures)