Jackson v. Mayweather

Case Overview: Jackson v. Mayweather

  • Court: Court of Appeal of California, Second Appellate District, Division Seven

  • Date of Opinion Filed: March 27, 2017

  • Court Docket Number: B266466

  • Citation: 10 Cal. App. 5th 1240; 217 Cal. Rptr. 3d 234; 2017 Cal. App. LEXIS 366

Parties

  • Plaintiff and Respondent: Shantel Jackson

  • Defendant and Appellant: Floyd Mayweather, Jr.

Subsequent History

  • Publication Status: Changed from Unpublished to Published on April 19, 2017.

  • Review Denied: Jackson v. Mayweather, 2017 Cal. LEXIS 4906 (Cal., June 28, 2017)

Prior History

  • Case appealed from Superior Court of Los Angeles County, No. BC555566, Judge Soussan G. Bruguera.

  • Previous ruling: Jackson v. Mayweather, 2017 Cal. App. Unpub. LEXIS 2230 (Cal. App. 2d Dist., Mar. 27, 2017)

Case Summary

Overview of Holdings

  1. Defendant's social media posts and comments about his relationship and Jackson's pregnancy constituted celebrity gossip related to public interest (under Code Civ. Proc., § 425.16, subd. (e)(4)).

  2. Defendant established that some of Jackson's claims for invasion of privacy, defamation, and emotional distress arose from protected activity under § 425.16.

  3. Plaintiff made a prima facie case for invasion of privacy based on defendant's publication of her sonogram and medical report, indicating sensationalism and an invasion of privacy.

  4. Outcome of case: Reversed in part and affirmed in part.

Counsel

  • For Defendant and Appellant: Rick Edwards, Inc., Rick Edwards.

  • For Plaintiff and Respondent: Allred Maroko & Goldberg, Michael Maroko, Marcus Spiegel, John S. West.

Judges

  • Opinion by: Perluss, P. J.

  • Concurring: Zelon and Segal, JJ.

Background

Jackson's Complaint

  • Filed: September 4, 2014

  • Narrative: Details an abusive relationship between Shantel Jackson (21, aspiring model/actress) and Floyd Mayweather, a recognized boxing champion.

  • Key Events:

    • 2006: Jackson meets Mayweather; they develop a romantic relationship.

    • August 2012: Allegations of physical abuse emerge during an argument.

    • April 2013: After continued issues, Jackson attempts to end the relationship; reconciles briefly but events prompt further discord.

    • July 2013: Mayweather allegedly steals Jackson's property; threats ensue regarding her safety and exposure.

    • November 2013: Jackson becomes pregnant with twins; shares sonogram with Mayweather.

    • January 2014: Jackson's pregnancy terminates.

    • May 2014: Mayweather posts on social media about the abortion and discusses Jackson’s cosmetic surgery on radio, leading to Jackson's invasion of privacy claims.

The Special Motion to Strike

a. Mayweather's Motion

  • Filed to dismiss five claims (including privacy and defamation) under § 425.16 as they were public interest issues.

  • Evidence: Jackson had a notable social media presence and promoted her celebrity status.

  • Claims: Jackson surrendered her privacy rights due to her public persona.

b. Jackson's Opposition

  • Jackson reiterated her account of the abusive relationship, emphasizing her privacy over medical matters and the inaccuracy of Mayweather's claims regarding her abortion and surgery.

c. Mayweather's Reply

  • Argued Jackson is a public figure; his statements about her were protected speech regarding public interest issues.

Trial Court's Ruling

  • Ruling: Denied Mayweather's motion; stated Jackson established a likelihood of success on several claims based on the evidence presented.

Legal Analysis: Section 425.16, The Anti-SLAPP Statute

a. Context

  • Definition: Protects against lawsuits aimed at chilling free speech on public issues.

  • Procedure: Two-step process - defendant shows claim arises from protected activity; then plaintiff must prove likelihood of success on the claim.

b. First Step

  • Mayweather's statements considered public forum activity as they appeared on social media and in a public interview.

  • Topics concerning Jackson, including her relationship issues, deemed matters of public interest.

c. Second Step

  • Jackson must demonstrate sufficient claims of privacy and emotional distress; must separate each valid claim.

Judgment and Rationale

a. Privacy Claims

  • Determined Jackson's claims for public disclosure of private facts were not valid for most of the disclosures made by Mayweather but valid concerning sonogram and medical records, which were considered sensational prying.

b. Defamation

  • Elements: Publication, falsity, defamatory statements, no privilege, damage caused.

  • Jackson failed to prove defamation for Mayweather's comments regarding the abortion as he had expressive latitude as a public figure.

c. Intentional Infliction of Emotional Distress

  • Standard: Must show extreme and outrageous behavior; Jackson's claims did not meet this threshold as Mayweather's statements, while damaging, did not constitute extreme misconduct.

Conclusion

  • Ruling: Order denying the special motion to strike was reversed regarding some claims (defamation and false light) while being affirmed regarding Jackson's claims founded on protected activity.

  • Both parties are responsible for their respective costs.