Amitay v. Jews for Jesus CA1/2

CourtCalifornia Court of Appeal
DecidedMay 28, 2026
DocketA174056
StatusUnpublished

This text of Amitay v. Jews for Jesus CA1/2 (Amitay v. Jews for Jesus CA1/2) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Amitay v. Jews for Jesus CA1/2, (Cal. Ct. App. 2026).

Opinion

Filed 5/28/26 Amitay v. Jews for Jesus CA1/2 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION TWO

ARIEL ZVOLON AMITAY, Plaintiff and Respondent, A174056

v. (San Francisco County Super. Ct. JEWS FOR JESUS, No. CGC-24-620902) Defendant and Appellant.

Ariel Amitay, an Orthodox Jewish rabbi, sued defendant Jews for Jesus (or JFJ), an evangelistic Christian ministry, for defamation and related claims based on social media postings by defendant that featured his photograph. JFJ filed a special motion to strike the complaint under the anti-SLAPP statute (Code Civ. Proc., § 425.16).1 The trial court denied the motion, finding that Amitay showed his claims had at least “minimal merit” to survive an anti-SLAPP motion. JFJ appeals. We find no error and affirm. BACKGROUND Jews for Jesus describes itself as an “evangelistic” ministry that “shares the Gospel of Christ to [its] Jewish brothers and sisters, both here in

1 “ ‘SLAPP’ is an acronym for ‘strategic lawsuit against public

participation.’ ” (Baral v. Schnitt (2016) 1 Cal.5th 376, 381, fn. 1 (Baral).)

1 the United States and around the world.” According to JFJ’s executive director, JFJ has expanded its “evangelistic” “outreach” to social media over the years. In December 2023, JFJ posted on its social media pages, including on Facebook and Instagram, a blurred photograph of an Israeli soldier wearing a yarmulke. Above the photograph was the following text attributed to “Nachman”: “ ‘Thank you for leaving at my home a copy of the New Testament. I look forward to reading it when I return home from the war’ – Nachman, a young Haredi soldier.”2 3 Amitay filed a complaint against JFJ, attaching screenshots of JFJ’s posts. He alleged that the photographs posted by JFJ were photographs of him, that they had been posted without his consent, and that defendant had defamed him, put him in a false light, and inflicted emotional distress. Amitay alleged that he was a Jewish Orthodox rabbi who had “dedicated his life to the study of the Jewish Orthodox faith and committed many years studying to become a rabbi,” recounting about a dozen years of study. He had finally gotten a job teaching at an institution in Israel where he had worked for two years, a position he described as his “dream job.” His job “suddenly came to an end as he was terminated . . . due to an egregious act by JFJ,”

2 “Hasid is the Hebrew word for ‘pious.’Hasidic Jews, or Hasidim, are the largest sub-group of Haredi Jews. Haredim are sometimes referred to as ‘ultra-Orthodox,’ although this term may be considered objectionable.” (Young Advocates for Fair Education v. Cuomo (E.D.N.Y. 2019) 359 F.Supp.3d 215, 221, fn. 4.) 3 Some of the posts went on to state: “One of the ways that God

provides for His people is through the generosity of other people around the World, like you. Because of your support, we were able to give a copy of the New Testament to Nachman and more than 1,000 Israelis in 2023!”

2 namely, “upload[ing] photos of Amitay on [its] social media pages.” He alleged: “JFJ posted a picture of [him] on their website giving the appearance that he supports JFJ’s cause. Not only was a photo uploaded, but the post included a caption also falsely expressing that [he] supported JFJ’s religious views.” Amitay alleged that he is “an Orthodox Jew, a more traditional branch of Judaism, which [has] starkly different views from JFJ.” He “never before associated with JFJ and disagrees with their religious views.” Amitay alleged that he had not consented to the posting or online dissemination of his photograph, and JFJ “knew or should have known from Amitay’s appearance in the photo that he did not support JFJ’s views.” He characterized his “demeanor” in the photograph, “including his long beard and black yarmulke,” as being that of a “traditional and conservative follower of Judaism, which is someone who would certainly not have supported JFJ.” He also noted that he “was wearing an army outfit.” He further alleged that an original photograph of Amitay had been taken by an unknown individual and posted online,4 and “JFJ intentionally cropped the original photo to zoom in on Amitay and exclude certain objects/elements (the Tefillin) which would inform viewers he is not a JFJ supporter.”5 In addition, the original photograph (Exhibit B) depicted Amitay standing next to a person who Amitay later described in his declaration as “visibly an Orthodox Jewish rabbi.” Amitay alleged that when his employer “saw the pictures posted online,” they “expressly stated that his termination was due to the posts

4 Amitay attached a screenshot showing this original photograph to his

complaint as Exhibit B. 5 Amitay’s declaration describes Tefillin as “a holy instrument that

Orthodox Jews use to pray every morning.”

3 online of him supporting JFJ, and that they could not condone or be associated with someone involved with JFJ or their views.” Amitay alleged that the posts were false because Amitay “has no affiliation with [JFJ] . . . and disagrees with [JFJ’s] religious views.” Amitay further alleged that he “was harmed as he lost his dream job and earnings,” and JFJ’s “conduct was a substantial factor in causing [Amitay’s] harm.” JFJ filed an anti-SLAPP motion, arguing that Amitay’s claims arose from protected free speech activity and Amitay could not show a probability of prevailing on the merits. In a supporting declaration, JFJ’s executive director stated that “Jews for Jesus operates openly and transparently” and “speak[s] directly . . . and publicly about who we are and why we believe that Jesus is the Jewish Messiah foretold in the Scriptures.” Its “posting on social media” is “aimed at opening the door to meaningful conversations about Jesus,” its “evangelistic” “outreach” on Facebook or Instagram or elsewhere is “an expression of our faith and our desire to see all people, Jewish and Gentile alike, come to know the love of God through His Son,” and JFJ has “expanded [its] efforts to digital platforms because that is where people are.” JFJ’s chief operating officer declared that its “standard protocol” is to “blur the faces of people in [its] content” to “obscure the identity of the person in the photo so as to avoid suggesting that this individual had personally endorsed or interacted with Jews for Jesus in any way.” In opposition to the anti-SLAPP motion, Amitay submitted declarations and exhibits. Amitay declared: “I have never been associated with JFJ. I do not follow or agree with their views or beliefs, and any implication to the contrary is false.” Amitay declared that he “was terminated by [his] employer” and attached the termination letter he received from his former employer, which states: “Documents (Exhibit 1 attached hereto) which, on the

4 face of it, serve as testimony to your associations with Christian bodies contrary to our Jewish faith, and to your position in the Seminary as an educator responsible for educating towards a belief in one God. After a hearing, which did not satisfy us, we are notifying you of your immediate dismissal.”6 Amitay declared that he has “applied for work since [his] termination from employment, but [has] been unable to secure a job.” He attached a letter from a potential employer, which states: “[H]aving heard of certain matters concerning you that have been made public, . . .

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Amitay v. Jews for Jesus CA1/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/amitay-v-jews-for-jesus-ca12-calctapp-2026.