JAKES v. YOUNGBLOOD
2:24-cv-01608
| W.D. Pa. | Apr 25, 2025Background
- Thomas Dexter Jakes sued Duane Youngblood and others for defamation, alleging Youngblood falsely accused Jakes of sexual abuse in online podcast episodes reaching over 100,000 viewers.
- The complaint asserts libel per se and civil conspiracy claims, stating the statements harmed Jakes’ reputation and career as a pastor.
- Youngblood filed a Special Motion to Dismiss under Pennsylvania’s Anti-SLAPP statute, asserting his statements were protected public expression and seeking attorneys’ fees.
- Youngblood also sought to file a counterclaim and add Jakes’s son, Jermaine Jakes, as a party based on a social media message.
- The court evaluated whether Pennsylvania’s Anti-SLAPP statute applies in federal court under diversity jurisdiction and whether Jermaine Jakes could be joined as a counterclaim defendant.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Applicability of § 8340.16 Anti-SLAPP pretrial motion | Motion should be denied; statute not effective | Motion permitted under § 8340.16 | Denied—statute not yet effective in Pennsylvania |
| Applicability of § 8340.15 immunity in federal court | Statute conflicts with Fed. Rules, so does not apply | Entitled to pretrial immunity via § 8340.15 | Denied—not applicable in federal court |
| Defendant’s right to file counterclaim | Motion moot; opposing counterclaim; improper statute | Sought leave to file based on social media message | Denied as moot |
| Joinder of Jermaine Jakes as counterclaim-defendant | Not a necessary party/personal jurisdiction defense | Sought permissive joinder as related party | Denied without prejudice; not a necessary party |
Key Cases Cited
- Abbas v. Foreign Pol’y Grp., LLC, 783 F.3d 1328 (D.C. Cir. 2015) (explains why federal courts in diversity apply Fed. Rules of Civil Procedure, not state anti-SLAPP statutes)
- Chamberlain v. Giampapa, 210 F.3d 154 (3d Cir. 2000) (articulates Erie doctrine’s application to substantive and procedural law in diversity cases)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (sets Rule 12(b)(6) pleading standard)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (sets Rule 56 summary judgment standard)
- United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (1966) (liberal construction of permissive joinder under Rule 20)