‘Weed 9’ Water Activists Present Legal Claim Against Sacramento Law Firm for Filing Malicious Lawsuit Aimed at Silencing Free Speech
April 30, 2020
The Weed, California, community members claim Churchwell White LLP knowingly filed meritless and illegal SLAPP suit against them on behalf of Roseburg Forest Products. Eugene, OR, April 29, 2020 — Protect the Protest task force member Civil Liberties Defense Center (CLDC) filed a lawsuit in the Siskiyou County Superior Court of… Read More
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A Letter to Southern NY Court: Open Donziger’s Trial
May 04, 2021
Chief Judge Laura Taylor SwainDaniel Patrick Moynihan United States CourthouseCourtroom 17C 500 Pearl St. New York, NY 10007-1312 Judge Loretta PreskaDaniel Patrick Moynihan United States CourthouseCourtroom 12A 500 Pearl St. New York, NY 10007-1312 Chief Judge Debra Ann LivingstonUnited States Court of Appeals for the Second CircuitThurgood Marshall U.S.Courthouse40 Foley SquareNew York, NY 10007… Read More
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AFTER FIVE-YEAR STRUGGLE, WEED, CA SECURES RIGHTS TO ITS SPRING WATER
March 11, 2021
March 11, 2021FOR IMMEDIATE RELEASE Contacts:Jim Taylor, WCWC President 530-938-2080 taylors96094@att.netBruce Shoemaker, WCWC media liaison, 612-770-9697 bshoe@bitstream.netToday the Weed City Council approved an agreement which secures, in perpetuity, the City’s rights to the high quality Beaughan Springs water upon which our community has relied for more than 110 years. This… Read More
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Alleged Assailants Retaliate Against #MeToo Movement
August 28, 2018
As #MeToo survivors share their experiences of sexual assault and domestic violence, many have faced retaliatory lawsuits. The power imbalance between survivors and alleged assailants is especially apparent in the revelations involving high profile men in Hollywood and the public eye. Examples abound: Bill Cosby,…
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An Environmental Advocate’s Guide to Avoiding Defamation and Other Publication Lawsuits
May 31, 2005
The First Amendment Project wrote this guide to help protect environmental advocates from defamation lawsuits. However, this resource provides guidance on avoiding defamation that is not only useful for environmental organizations, but a broader range of civil society groups.
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Billionaires Bully the Media
August 28, 2018
The Harvey Weinstein scandal raised awareness of the tactics used by billionaires in the United States to keep the media from publishing critical stories. Weinstein used several tactics to prevent the sexual assault story from being published, including threatening to sue the New York Times for $50 million.
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California Anti-SLAPP Project
August 10, 2018
The California Anti-SLAPP Project (CASP) is a law firm that fights against SLAPPs and protects the First Amendment. The firm’s website has a number of resources to help those targeted by SLAPPs. While the resources are geared towards those in California, they provide a useful reference for individuals and…
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Case Update: Despite Retreat from City of Weed, ‘Weed 9’ Remain Resolute in Fight Against SLAPP
August 12, 2019
On August 11, Water for Citizens of Weed, California (WCWC) issued a press release announcing that the City of Weed ended its legal battle with Roseburg Forest Products and has conceded the rights to the Beaughan Springs, the main source of clean drinking water in the area. The City… Read More
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Chevron: Protect the Protest’s Corporate Bully of the Year
May 29, 2019
Today, activists gathered outside Chevron’s annual meeting to tell CEO Michael Wirth that the company must stop being a corporate bully. Speakers at the event said that the company has spent over $2 billion and engaged over 2,000 lawyers to avoid accountability for its environmental violations in Ecuador. Share this… Read More
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Coal Baron Files SLAPPs Against Those Who Criticize His Labor Practices
August 28, 2018
Robert Murray is a notorious coal baron who leads the country’s largest privately owned coal company, the Murray Energy Corporation. The company has been repeatedly sanctioned for failing to meet miner safety standards. Mr. Murray has close ties to President Trump. In June 2017, Murray sued comedian John…
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Communities Demand Accountability and an End to Chevron’s Pollution
May 21, 2021
For Immediate Release May 21, 2021 Contacts: Shoshana Wechsler at swechs@sonic.net +1.510.332.4110 Nyunt Than at nyuntthan@gmail.com +1.510.220.1323 Paul Paz y Miño at paz@amazonwatch.org +1.510.773.4635 Communities Demand Accountability and an End to Chevron’s Pollution During the 8th annual Anti-Chevron Day, affected frontline communities from around the world continue… Read More
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Companies Strike Back Against Negative Customer Reviews Online
August 28, 2018
Several companies have sued consumers who post negative reviews online. In December 2012, the Virginia Supreme Court reversed a controversial lower court decision that forced a customer, Jane Perez, to remove a negative review of a contractor on Yelp. The contractor, Christopher Dietz, had sued Ms. Perez for $750,000…
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Defamation, Libel, Slander…and Other Common SLAPP disguises
August 10, 2018
The California Anti-SLAPP Project created this factsheet to explain the types of legal claims (such as defamation, invasion of privacy, and conspiracy) that are often used to disguise a SLAPP. The definitions on this sheet apply specifically to California law, but provide a general overview that can…
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Defending Against a SLAPP
August 10, 2018
The California Anti-SLAPP project created this factsheet to describe the basic parts of litigation involving a SLAPP. Although the content is specific to California laws, it provides a general overview that can be useful for individuals and organizations facing SLAPPs in other jurisdictions.
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EFF: Why We Can’t Support Modifications to Texas’ Anti-SLAPP Law
May 21, 2019
The Electronic Frontier Foundation analyzes Big Business’ “reform” of Texas’ anti-SLAPP law. This article is reprinted with permission from EFF’s website. Earlier this year, a critical free speech law in Texas came under attack. Texas bill H.B. 2730, as… Read More
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Encyclopedia of Types of SLAPPs
August 28, 2018
Legal bullies never admit that they are filing a “strategic lawsuit against public participation” (SLAPP); SLAPPs come disguised as legitimate legal claims. Here are some of the most common types of legal theories used in SLAPPs. Note: these legal theories all appear in legitimate lawsuits, as well; in each case,…
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Energy Transfer Partners and Kasowitz Law Firm SLAPP Against Environmental Organizations
August 10, 2018
In August, 2017 Energy Transfer Partners (ETP) – which is building the Dakota Access Pipeline – filed a USD$900 million lawsuit in the United States District Court for the District of North Dakota alleging violations of Racketeer Influenced and Corrupt Organizations Act (RICO) and other claims against Greenpeace International, Greenpeace,…
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ExxonMobil SLAPP Against Climate Change Activists
August 28, 2018
In November 2016, ExxonMobil subpoenaed over ten environmental organizations and individuals, as part of an effort to intimidate and chill the First Amendments rights of climate change activists. EarthRights International represents one of these activists, Carroll Muffett, the president of the Center for International Environmental Law.
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Forestry Company Faces Challenge to Its “Responsible Timber” Certification After Waging Intimidation Campaign Against Local Community
February 27, 2019
WEED, CALIFORNIA – Citizens of Weed, California filed a complaint today with the Forest Stewardship Council (FSC) after Oregon-based Roseburg Forest Products refused to stop its abusive tactics in a bid to privatize the community’s main source of drinking water. The complaint alleges that Roseburg,… Read More
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Green Group Holdings SLAPP Against Community Activists
August 10, 2018
The ACLU represented community activists in Uniontown, Alabama who were sued for defamation when they expressed opposition to the dumping of hazardous coal ash in a landfill in their town. The landfill operator, Green Group Holdings, sued the residents for $30 million. In February 2017, the parties reached a settlement in…
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Green Groups: Suits to Silence Them on the Rise
April 14, 2017
In this article for Bloomberg Law, Peter Hayes describes a SLAPP filed against residents of Uniontown, Alabama who opposed the dumping of toxic material in a landfill in their community. While it’s difficult to estimate the number of SLAPPs, it’s clear…
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Guarding Against the Chill: A Survival Guide for SLAPP Victims
May 31, 2018
The First Amendment Project created this handbook to help individuals and organizations identify SLAPPs and protect themselves. This includes preemptive actions to reduce exposure to SLAPPs and actions to take if a SLAPP bully targets you or your organization.
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How Litigation Throttles Civic Advocacy
May 22, 2017
Bunny Mcdiarmid, Executive Director of Greenpeace International discusses how corporations are using SLAPPs to target advocacy groups. This article explains why corporations would pursue a lawsuit that they expect to lose: “In many ways, hiring goons is a lot easier and…
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How the Wealthy Use Frivolous Lawsuits to Silence Activists, Journalists, and Even Victims of Sexual Violence
September 12, 2018
In this article for Salon, Amanda Marcotte reports on the launch of the Protect the Protest task force, as well as the wide range of public interest organizations affected by SLAPPs. This includes, for example, media organizations, environmental activists, and sexual…
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Human Rights Watch: Green Activists are Fighting the Great Fight – but are being Dragged Down by Petty Lawsuits
May 10, 2019
In Newsweek, Marcos Orellana of Human Rights Watch describes how companies worldwide are bringing baseless lawsuits against environmental activists. As Orellana describes, the purpose of this tactic is “to suppress environmental defenders’ effectiveness by intimidating them and burdening them with… Read More
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International Organizations Demand DOJ Review Chevron’s Retaliatory Litigation against Human Rights Attorney Steven Donziger
February 17, 2021
Read the letter here Washington, D.C. – Thirteen international human rights and environmental watchdog organizations sent an open letter to the U.S. Department of Justice asking it to launch a high-level review of the retaliatory “SLAPP” lawsuits Chevron brought against the lawyer who helped 30,000 Indigenous peoples… Read More
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Landfill Operator Tries to Silence Community Activists in Alabama
August 28, 2018
Uniontown, Alabama is one of the poorest communities in the United States. Its population is 91% African American, and half of its residents live below the poverty line. Georgia-based Green Group Holdings operates a landfill in the town. When the company dumped millions of tons of toxic coal ash…
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Law Firm Uses Anti-Mafia Law to Harass Environmentalists
August 28, 2018
New York City-based law firm Kasowitz Benson Torres LLP is attempting to use an anti-mafia law to stifle the free speech of civil society organizations. In July 2018, a federal judge dismissed a lawsuit filed by Canadian logging giant, Resolute Forest Products, against environmental organizations Greenpeace and Stand.earth. Resolute and…
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Lawmakers Attempt to Open the Door for “Ag Gag” SLAPPs
December 31, 2017
Since 2012, at least 18 states have attempted to pass “ag gag” laws that prohibit undercover investigations and whistleblowing in animal agricultural facilities. In this article, the Center for Constitutional Rights(CCR) describes the amicus briefs it has submitted in cases challenging Idaho’s and Utah’s ag-gag laws. This report by the…
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Maggy Hurchalla, sued by a mining company, tells you to keep your chin up!
July 24, 2020
“Can you be sued for trying to save the world?” Maggy Hurchalla Two years ago, a jury decided Maggy Hurchalla, 79 years old, should pay $4.4 million to Lake Point Restoration, a company running limestone mining operations in Martin County, Florida. A lifelong Florida resident, Ms. Hurchalla came… Read More
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New York Times Feature: Maggy Hurchalla, Florida Environmental Activist, Continues SLAPP Fight Despite Recent Loss
September 18, 2019
In a recent New York Times article, Florida environmental activist Maggy Hurchalla discussed the ongoing SLAPP suit that was brought against her by Florida mining Company, Lake Point Restoration. Read More
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Oil Giant Uses Court Procedures to Harass Climate Change Advocates and Scientists
August 28, 2018
During the past five years, climate change activists, scientists, and investigators have uncovered evidence that oil giant ExxonMobil first learned about the dangers of climate change decades ago, yet chose to conceal this information from its customers and the public. This information now forms the basis of several multi-million…
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Police Officers Attempt to Hold Black Lives Matter Activists Liable for Other Protesters’ Actions
August 28, 2018
Following a series of protests in 2016 and 2017, several injured police officers sued the Black Lives Matter movement. In late 2016, for example, a police officer in Baton Rouge, Louisiana, brought a lawsuit against Black Lives Matter, the hashtag #BlackLivesMatter, and DeRay Mckesson, a high profile activist associated with…
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Press Release: SLAPP Protection Act is a Critical Step to Defend American Democracy
September 15, 2022
Today, U.S. Representative Jamie Raskin (D-MD) introduced the SLAPP Protection Act, landmark legislation that would protect free speech and uphold the integrity of our courts. Read More
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Resolute Forest Products and Kasowitz Law Firm SLAPP Against Environmental Organizations
August 28, 2018
On May 31, 2016 Resolute Forest Products filed a $300 million (CAD – Canadian dollars) lawsuit in the United States District Court for the Southern District of Georgia alleging violations of the Racketeer Influenced and Corrupt Organizations Act (RICO) and other claims against Greenpeace International, Greenpeace, Inc., Greenpeace Fund, Inc.,…
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Responding to Steven Donziger’s Conviction
August 06, 2021
After decades of legal battles with Chevron, Steven Donziger has been convicted of six counts of criminal contempt of court by Judge Loretta Preska. Preska was appointed to the case by Judge Lewis Kaplan who decided an infamous RICO case in Chevron’s favor in 2014 and who held Donziger in civil… Read More
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SLAPPed: A Tool for Activists
May 15, 2014
The ACLU of Ohio developed this guide to help activists better understand SLAPPs and how to defend against them. The guide includes a brief history of SLAPPs and a description of modern SLAPPs, including those against free speech online.
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SLAPPs: Getting Sued for Speaking Out (1996)
January 01, 1996
This book, by the two professors who coined the term “SLAPP,” charts the history of SLAPPs. The book examines the history of how the courts have addressed SLAPPs and looks at trends during the 1970s-1990s. An excerpt of the book is available here. The full book can…
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SLAPPs: Strategic Lawsuits against Public Participation (1989)
September 01, 1989
The Pace Environmental Law Review published this article in 1989 by one of the two professors who coined the term “SLAPP.” This article analyzes the legal implications of SLAPPs, while a counterpart article by Penelope Canan examines SLAPPs from a sociological perspective.
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South African Advocacy Organizations Launch Anti-SLAPP Campaign: Asina Loyiko
June 28, 2019
Last month, a network of South African civil society organizations launched the joint advocacy campaign Asina Loyiko: United Against Corporate Bullying. Read More
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Steven Donziger Is Finally Free. Onward Toward Justice for the People of Ecuador!
April 28, 2022
By Paul Paz y MiñoOriginally published in Eye on the Amazon Today, human rights lawyer Steven Donziger woke up free, marking the closure of the latest chapter in Chevron’s scheme to evade justice for contaminating the Amazon rainforest. Now all eyes turn back to the true… Read More
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Student Surveillance Vendor Proctorio Files SLAPP Lawsuit to Silence A Critic
March 08, 2021
Originally posted on the EFF website. Reposted with permission. During the pandemic, a dangerous business has prospered: invading students’ privacy with proctoring software and apps. In the last year, we’ve seen universities compel students to download apps that collect their face images, driver’s license data, and network information. Students… Read More
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Supreme Court Amicus Brief in Support of Florida Community Advocate SLAPPed by Mining Company Submitted
October 13, 2020
Reposted from PTP members, Civil Liberties Defense Center. Eugene, OR—On Saturday, October 10th, CLDC and the Protect the Protest task force filed an amicus brief in support of Maggie Hurchalla, a Florida community elder and leader who dared to ask her elected officials to reject a mining company’s proposal… Read More
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The Chevron-Ecuador Case Is Critical to the Climate Justice Movement
May 27, 2021
Originally published via Amazon Watch By Paul Paz y Miño Yesterday, May 26th, was Chevron’s 11th shareholder meeting since the company lost a historic $9.5 billion judgement for deliberately polluting the Ecuadorian Amazon. Since then, many more Ecuadorians have gotten sick and died awaiting justice, as Chevron pulled its… Read More
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The Dakota Access Pipeline Company Is Abusing the Judicial System to Silence Dissent
March 04, 2019
The ACLU discusses how pipeline company Energy Transfer is abusing the judicial system in order to suppress the rights of activists. The article is available on the ACLU’s website and is re-posted here with permission. In a win for free speech, a federal court in North Dakota recently… Read More
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Too Far, Too Often: Energy Transfer Partners’ Corporate Behavior On Human Rights, Free Speech, and the Environment
June 30, 2018
In June 2018, Greenpeace US published a report documenting the tactics used by Energy Transfer Partners – developer of the Dakota Access Pipeline – to intimidate and silence opponents of the project. This includes SLAPPs against Greenpeace and other activists involved in the campaign against the pipeline.
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Trump’s Mob Violence Reminds Us Why We Need To Defend Protest
January 25, 2021
We stand unequivocally behind the right to protest. And we stand unequivocally behind the fact that what happened on January 6, 2021 was NOT a protest. They were not protestors, but white supremacist, anti-democratic, insurrectionists attacking our country and our people.The organizers of the attack on the U.S. Capitol planned… Read More
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Where Protests Flourish, Anti-Protest Laws Follow
February 17, 2017
This article by the ACLU describes efforts by state legislatures to pass laws (which are unconstitutional) to curb protests.
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U.N. must examine growing trend of U.S. corporations using courts to silence dissent, says free speech group
January 15, 2019
WASHINGTON, DC — Protect the Protest, an international task force of over 20 organizations working to protect free speech, is calling on the U.N. Human Rights Committee to address the growing trend of corporations and individuals in the United States using Strategic Lawsuits Against Public Participation (SLAPPs) to… Read More
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The Term “Eco-Terrorist” is Being Used to Harass Activists
January 03, 2019
In an article for Grist, Justine Calma and Paola Rosa-Aquino discuss a 1990s tactic that is growing in popularity once again: labeling activists as “eco-terrorists.” Across the world, we are witnessing growing efforts by governments and corporations to silence environmental activists. According to Calma and Rosa-Aquino, “The consequences of… Read More
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Pipeline Protester Fights Back Against Corporation’s Sprawling, Outlandish Lawsuit
December 21, 2018
BISMARCK, ND — Krystal Two Bulls, an Oglala Lakota and Northern Cheyenne U.S. army veteran and environmental and Indigenous rights activist, today urged a federal court to dismiss a racketeering lawsuit filed against her for her role in standing for land, water, and her People against the Dakota Access Pipeline. Read More
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BuzzFeed Defeats SLAPP Arising Out of Trump-Russia Scandal
December 20, 2018
MIAMI, FLORIDA – Yesterday, a federal court dismissed a defamation lawsuit brought by a Russian technology entrepreneur against BuzzFeed News. In January 2017, BuzzFeed published the now-famous dossier produced by Christopher Steele, which includes allegations linking Donald Trump to Russia. Aleksej Gubarev, one… Read More
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The ‘Weed 9’ Rallies Against Corporate Water Grab and Legal Bullying
December 18, 2018
SPRINGFIELD, OREGON – Residents of Weed, California are rallying today outside the headquarters of Roseburg Forest Products to demand that the Springfield-based company cease its aggressive campaign to deprive them of their clean drinking water. Over 20 residents of Weed made the five hour journey to… Read More
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Activists Defeat SLAPP Brought By Company With White Supremacist Ties
December 04, 2018
On November 30, 2018, San Francisco’s Superior Court issued an order granting anonymous antifascists’ motion to quash a subpoena that sought to uncover the identities of the antifascists. Civil Liberties Defense Center attorney Cooper Brinson urged the court to uphold the First Amendment rights of the antifascists to engage in anonymous… Read More
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U.S. House Committee Will Call Off “Witch Hunt” Against Environmental Groups
December 04, 2018
Throughout 2018, House Natural Resources Committee chairman Rob Bishop (R-UT) undertook a harassment campaign against environmental groups, accusing them of working as “foreign agents.” The incoming chairman, Rep. Raul Grijalva (D-AZ), has announced that he will discontinue the use of these tactics. Grijalva told the progressive blog ThinkProgress, “I’m… Read More
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Energy Transfer Continues Aggressive Attempts to Silence Opposition: Greenpeace Report
October 18, 2018
WASHINGTON, DC, October 18, 2018 — A new Greenpeace USA report “Still Too Far: Energy Transfer Continues to Display Concerning Corporate Behavior” compiles recent evidence that the pipeline company is still aggressively trying to silence opposition to its pipelines across the United States, despite calls from communities, financial institutions,… Read More
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Electronic Frontier Foundation Helps to Launch the “Protect the Protest” Task Force
September 14, 2018
David Ruiz describes how the Electronic Frontier Foundation (EFF) has worked to tackle SLAPPs, and how the Protect the Protest task force will help. Ruiz said, “EFF feels right at home in Protect the Protest. We’ve represented individuals facing SLAPPs, we’ve connected others with legal help, and we’ve repeatedly… Read More
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Court Shuts Down Monsanto’s SLAPP Against Avaaz
September 06, 2018
A Manhattan judge has denied an effort by agribusiness giant Monsanto to subpoena communications and privacy data from the campaigning group Avaaz. In issuing his decision, Judge Slomo Hagler said, “The subpoena itself would send a tremendous chilling effect through not… Read More
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Hollywood’s Notorious Men Retaliate Against #MeToo Movement
August 20, 2018
Valentina Stackl of EarthRights International discusses the pervasive use of SLAPPs against #MeToo survivors. Stackl writes, “As #MeToo survivors bravely share their experiences of sexual assault and intimate partner violence, they endure criticism, threats, and renewed emotional trauma. They also face retaliatory lawsuits.”… Read More
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Lawsuit Against Greenpeace Raises Freedom of Speech Concerns
August 10, 2018
Human Rights Watch discusses a SLAPP filed by Resolute Forest Products against Greenpeace and Stand.earth, which uses the U.S. Racketeer Influenced and Corrupt Organizations (RICO) Act. Human Rights Watch notes that SLAPPs pose a significant threat to the freedoms of expression, assembly, and association. Read More
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The New Corporate Playbook, Or What To Do When Environmentalists Stand In Your Way
August 10, 2018
In the Huffington Post, Katie Redford of EarthRights International discusses the growing trend in which American corporations use the court system to silence their critics. Common tactics in the “corporate playbook” include retaliatory litigation; attacks on funding sources, partners, and clients; corporate espionage and surveillance; and using Congress… Read More
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Defending Dissent: SLAPP Lawsuits and the Fight For Free Speech
August 10, 2018
The International Corporate Accountability Roundtable (ICAR) discusses a SLAPP filed by Resolute Forest Products against Greenpeace and Stand.earth, which uses the U.S. Racketeer Influenced and Corrupt Organizations (RICO) Act. ICAR discusses the threat that this SLAPP poses to free speech in the United States. Read More
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“I Say Corporations are Destroying the Planet. So Sue Me?”
August 10, 2018
The Center for Constitutional Rights (CCR) discusses two SLAPPs brought by the law firm Kasowitz Benson Torres against Greenpeace and other environmental organizations. One is a SLAPP on behalf of Resolute Forest Products against Greenpeace and Stand.earth, using the U.S. Racketeer Influenced and Corrupt Organizations (RICO) Act. Read More
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7 Things You Need to Know About ETP’s Lawsuit Against Greenpeace
August 10, 2018
Greenpeace provides background on a SLAPP brought by Energy Transfer Pipelines, the company behind the Dakota Access Pipeline, against Greenpeace, Earth First!, and BankTrack. The SLAPP uses the U.S. Racketeer Influenced and Corrupt Organizations (RICO) Act. Read More
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The Day I Was Treated Like a Mobster and Served a $300 Million Lawsuit for Defending Forests
August 10, 2018
Greenpeace’s senior forest campaigner Daniel Brindis describes his experience being sued as a Greenpeace employee by Resolute Forest Products for his public interest work. Read More
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Logging Giant Uses Bogus Lawsuits to Intimidate Environmental Activists
August 10, 2018
EarthRights International discusses a SLAPP filed by Resolute Forest Products against Greenpeace and Stand.earth, which uses the U.S. Racketeer Influenced and Corrupt Organizations (RICO) Act. EarthRights International analyzes how the case poses a broad threat to civil society movements in the United States. Read More
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Judge Slams Pipeline Corporation for Frivolous Legal Claims Against Activists
August 03, 2018
On August 3, 2018, a federal court blocked Energy Transfer Partners, developer of the Dakota Access Pipeline, from continuing a SLAPP against the Earth First! Movement. The court rejected the company’s allegations as factually unsupported. Read More
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Court Dismisses Frivolous and “Dangerously Broad” Lawsuit Against NGO BankTrack for Opposing Dakota Access Pipeline
July 25, 2018
On July 25, 2018, a federal court dismissed a SLAPP lawsuit by developers of the Dakota Access Pipeline against BankTrack, a human rights and environmental NGO dedicated to ensuring that private banks engage in sustainable financing. Read More
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Dangerous Lawsuit against Greenpeace Threatens News Organizations and First Amendment
February 19, 2018
This article by Camille Fassett of the Freedom of the Press Foundation describes a SLAPP brought by Energy Transfer Partners — the company behind the Dakota Access Pipeline — against Greenpeace and other environmental organizations. Although this SLAPP targets environmental organizations, Freedom of the Press Foundation discusses… Read More
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