SALAAM v. TRUMP
2:24-cv-05560
| E.D. Pa. | Jun 27, 2025Background
- Plaintiffs (Yusef Salaam, Raymond Santana, Kevin Richardson, Antron Brown, Korey Wise) are the exonerated defendants from the notorious "Central Park Five" case.
- Defendant Donald J. Trump made public statements about plaintiffs during the 2024 Presidential campaign, referencing their prior convictions and exonerations.
- Plaintiffs brought claims against Trump for defamation, false light, and intentional infliction of emotional distress (IIED).
- Trump moved to dismiss under Pennsylvania’s Uniform Public Expression Protection Act (“Anti-SLAPP Statute”), arguing immunity from suit for protected public expression.
- Trump explicitly did not move under Federal Rule of Civil Procedure 12(b)(6).
- The key question before the court: Does Pennsylvania’s Anti-SLAPP Statute apply in federal court?
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Pennsylvania’s Anti-SLAPP statute applies in federal court | Implied: Federal Rules, not state Anti-SLAPP, govern procedure in federal court. | The statute applies and provides defendant immunity from suit for protected public expression. | Statute does NOT apply in federal court. |
| Whether § 8340.15 of the statute directly collides with Federal Rules | Federal Rules 12 & 56 govern pretrial claim disposition, so state law is displaced. | Statute and Rules don't conflict because § 8340.15 mirrors Rule 12(b)(6) language. | Collision exists; Federal Rules control. |
| Whether Rules 12 and 56 violate the Rules Enabling Act | Rules regulate procedure and are valid under the Rules Enabling Act. | Did not argue Rules 12/56 violate Enabling Act. | No violation; Rules are valid. |
| Whether to grant dismissal based solely on statute | Should not be dismissed under state law in federal court; only proper rule is 12(b)(6). | Seeks dismissal under Anti-SLAPP alone, not on usual federal grounds. | Motion to dismiss denied; state law not applied. |
Key Cases Cited
- Erie R.R. Co. v. Tompkins, 304 U.S. 64 (federal courts apply state substantive law, not procedural)
- Hanna v. Plumer, 380 U.S. 460 (direct collision between federal rule and state law triggers use of federal rule)
- Guar. Tr. Co. of N.Y. v. York, 326 U.S. 99 (outcome-determinative test under Erie doctrine)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (standard for pleading plausibility under Rule 12(b)(6))