Pryor v. Brignole
231 Conn.App. 659
Conn. App. Ct.2025Background
- Pryor, a former associate attorney, sued Brignole and his law firm for alleged breach of a contractual nondisparagement clause after anonymous letters regarding Pryor’s arrest and criminal charges were sent to news outlets.
- The contract at issue was part of a settlement agreement resolving a prior civil action between Pryor and the law firm.
- Brignole and the law firm filed special motions to dismiss under Connecticut’s anti-SLAPP statute (CT Gen Stat § 52-196a), which allows early dismissal of lawsuits based on actions implicating First Amendment rights on matters of public concern.
- The trial court denied defendants' motions, finding the defendants had not admitted to engaging in the alleged speech and thus could not invoke anti-SLAPP protections.
- On interlocutory appeal, the Appellate Court dismissed for lack of a final judgment, but the Supreme Court held the ruling was appealable and remanded for further proceedings.
- The Appellate Court then addressed whether a defendant must admit to the conduct alleged to invoke anti-SLAPP protections.
Issues
| Issue | Pryor's Argument | Brignole's Argument | Held |
|---|---|---|---|
| Whether defendants must admit to the alleged conduct to invoke anti-SLAPP protections (first prong) | Defendants must admit engaging in speech to benefit from anti-SLAPP | The analysis should focus on the complaint's allegations, not party admissions | Admission not required; analysis centers on the complaint’s allegations |
| Whether the anonymous letter about Pryor's criminal charges was speech on a "matter of public concern" | Alleged conduct did not involve a public concern | The charges and letter related to public concern, specifically criminal prosecution and attorney conduct | Allegations concerned a matter of public concern |
| Timeliness of defendants’ special motions to dismiss | Motions were untimely and thus waived | Good cause existed for delay and plaintiff asked court to reach merits | Motions implicitly deemed timely by court, especially as plaintiff invited merits decision |
| Effect of possible complaint amendment on anti-SLAPP analysis | Not directly argued; court deferred amendment | Defendants could respond to amended complaint if permitted | Not at issue in this decision |
Key Cases Cited
- Lafferty v. Jones, 336 Conn. 332 (2020) (discusses special motions to dismiss under Connecticut anti-SLAPP statute)
- Smith v. Supple, 346 Conn. 928 (2023) (interprets scope and procedure of anti-SLAPP special motions to dismiss)
- Gleason v. Smolinski, 319 Conn. 394 (2015) (public allegations of crime generally are speech on matters of public concern)
- Squeglia v. Squeglia, 234 Conn. 259 (1995) (crimes involving parents and children are public concerns)
- Priore v. Haig, 344 Conn. 636 (2022) (policy and interpretation of anti-SLAPP procedures in Connecticut)