Leiendecker v. Asian Women United of Minnesota
2014 Minn. LEXIS 289
| Minn. | 2014Background
- Over 10 years, Leiendecker and AWUM engaged in five lawsuits, with this case being the fifth.
- AWUM sought dismissal under Minnesota’s anti-SLAPP statutes to deter participation in government actions.
- District court denied AWUM’s motion on most claims but allowed a malicious-prosecution claim to survive the anti-SLAPP analysis, which the court of appeals affirmed; this Court reverse.
- Central issue: whether a responding party must produce evidence to defeat an anti-SLAPP motion or may rely solely on allegations in the complaint.
- Plaintiffs allege multiple claims; only malicious prosecution remains independently actionable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Must respond to anti-SLAPP with evidence | Leiendecker argues allegations suffice; no need for evidence at this stage | AWUM contends responding party must produce clear and convincing evidence | Responding party must produce evidence; allegations alone are insufficient |
| Effect of savings clause on burden | Savings clause preserves constitutional rights and could avoid burden shift | Savings clause does not override statutory text requiring evidence | Savings clause does not alter the plain requirement to produce evidence |
| Relation of anti-SLAPP framework to other standards | Constitutional concerns may arise from the framework | Statutes compel a burden-shifting analysis separate from summary judgment | Anti-SLAPP framework is not compatible with a summary-judgment standard; requires production and findings on immunity |
Key Cases Cited
- Leiendecker v. Asian Women United of Minn., 834 N.W.2d 741 (Minn.App.2013) (court on anti-SLAPP burden and evidentiary requirements)
- Stengrim, 784 N.W.2d 884 (Minn.2010) (establishes procedural framework for anti-SLAPP analysis)
- Marchant Inv. & Mgmt. Co. v. St. Anthony W. Neighborhood Org., Inc., 694 N.W.2d 92 (Minn.App.2005) (previous reliance on pleadings standards in anti-SLAPP context criticized)
- Nexus v. Swift, 785 N.W.2d 771 (Minn.App.2010) (addressed jury trial and anti-SLAPP procedure; criticized Marchant's approach)
- Braylock v. Jesson, 819 N.W.2d 585 (Minn.2012) (defines burdens of proof, production, and persuasion)