C. Napoleon Barnwell v. Ankur Pankaj Trivedi

CourtCourt of Appeals of Georgia
DecidedNovember 15, 2022
DocketA22A1466
StatusPublished

This text of C. Napoleon Barnwell v. Ankur Pankaj Trivedi (C. Napoleon Barnwell v. Ankur Pankaj Trivedi) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
C. Napoleon Barnwell v. Ankur Pankaj Trivedi, (Ga. Ct. App. 2022).

Opinion

THIRD DIVISION DOYLE, P. J., REESE, J., and SENIOR APPELLATE JUDGE PHIPPS

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

November 15, 2022

In the Court of Appeals of Georgia A22A1466. BARNWELL v. TRIVEDI.

DOYLE, Presiding Judge.

C. Napoleon Barnwell sued Ankur Pankaj Trivedi for defamation. Trivedi

moved to dismiss the case for failure to state a claim and for violation of Georgia’s

anti-SLAPP statute.1 The court granted the motion, and Barnwell appeals. We affirm

for the reasons that follow.

The record shows that Barnwell and Trivedi are licensed Georgia attorneys

who at one point represented opposing parties in a case in the Superior Court of

DeKalb County.2 Barnwell employed law student Renee E. Taylor, who conducted

depositions in the case. After suspecting and confirming that Taylor was not a

1 See OCGA § 9-11-11.1. 2 See Moore v. Collins, Superior Court of DeKalb County, CAFN:20A80118. licensed member of the Bar when she took the deposition,3 Trivedi secured transcripts

of depositions from matters handled by other law firms in which Taylor also

conducted depositions prior to becoming licensed to practice law. As a result of his

investigation, Trivedi filed in the State Bar of Georgia a grievance against Taylor for

holding herself out as an attorney and conducting depositions prior to obtaining her

provisional license to practice law and a grievance against Barnwell for facilitating

and promoting the unauthorized practice of law (“UPL”) by Taylor.

Trivedi also moved for sanctions in the DeKalb County case. At the hearing on

the motion, Barnwell took the position that Taylor, his intern and a law student at

John Marshall Law School, was authorized to practice law under the Supreme Court

of Georgia’s Student Practice Rule.4 At the hearing, the judge concluded that Taylor’s

3 On January 19, 2021, after she took the deposition in the DeKalb County case, Taylor was provisionally licensed to practice law. See April 17, 2020 Supreme Court of Georgia order: “IN RE: PROVISIONAL ADMISSION TO THE PRACTICE OF LAW IN GEORGIA” (providing provisional admission to certain recent law school graduates in response to postponement of the July 2020 administration of the Georgia bar examination resulting from COVID-19). (https://www.gasupreme.us/court-information/court_corona_info/). 4 See Student Practice Rule, Ga. Supreme Court Rule 92 (providing permissible activities by a law student registered to practice pursuant to the rule) (https://www.gasupreme.us/rules/rules-of-the-supreme-court-of-georgia/#XV8-15- 15).

2 actions were not permitted under the Student Practice Rule and that Barnwell violated

the rule by permitting her to take the depositions.

Barnwell filed the instant case against Trivedi in the Superior Court of

Gwinnett County, alleging claims for defamation/slander by: (1) filing the motion for

sanctions in the DeKalb County case; (2) filing the Bar complaint; and (3) expressing

to other lawyers that Barnwell engaged in UPL. Trivedi moved to dismiss the case for

failure to state a claim and for violation of Georgia’s anti-SLAPP statute. At the

hearing on the motion to dismiss, Barnwell abandoned his claims based on Trivedi’s

statements in the Bar complaint and in the sanctions motion in the DeKalb County

case, conceding that the statements constituted protected speech under Georgia law,5

but he argued that his claim that Trivedi slandered him to other attorneys remained

actionable.

The trial court dismissed Barnwell’s case, finding that he failed to establish a

possibility that he would prevail on his remaining claim because there was no

5 See OCGA §§ 51-5-8 (“All charges, allegations, and averments contained in regular pleadings filed in a court of competent jurisdiction, which are pertinent and material to the relief sought, whether legally sufficient to obtain it or not, are privileged. However false and malicious such charges, allegations, and averments may be, they shall not be deemed libelous.”); 9-11-11.1 (b) (1), (c) (1), (2)”).

3 evidence that Trivedi made statements regarding Barnwell assisting in Taylor’s UPL

to any lawyers other than those in Trivedi’s law firm, nor was there evidence that

Trivedi said anything that was not already a matter of public record. This appeal

followed.

Barnwell argues that the trial court erred by dismissing his case pursuant to the

anti-SLAPP statute. We disagree.

“The General Assembly enacted the anti-SLAPP statute to encourage

Georgians to participate ‘in matters of public significance and public interest through

the exercise of their constitutional rights of petition and freedom of speech.’”6 The

statute provides protection for claims

against a person . . . arising from any act of such person . . . which could reasonably be construed as an act in furtherance of the person’s . . . right of petition or free speech under the Constitution of the United States or the Constitution of the State of Georgia in connection with an issue of public interest or concern. . . .7

6 RCO Legal, P.S., Inc. v. Johnson, 347 Ga. App. 661, 666 (2) (a) (820 SE2d 491) (2018), quoting OCGA § 9-11-11.1 (a). 7 OCGA § 9-11-11.1 (b) (1).

4 A claim arising from an act described in the anti-SLAPP statute is subject to a motion

to strike (or, as pleaded in this case, a motion to dismiss), “unless the court

determines that the nonmoving party has established that there is a probability that

the nonmoving party will prevail on the claim.’”8

Thus, there is a two-step analysis of an anti-SLAPP motion to strike (or, as in

this case, a motion to dismiss based on the statute).9 “First, the court must decide

whether the party filing the anti-SLAPP motion . . . has made a threshold showing

that the challenged claim is one arising from protected activity. If so, the court must

decide whether the plaintiff has established that there is a probability that the plaintiff

will prevail on the claim.”10 When making that determination, “a court shall consider

the pleadings and the supporting and opposing affidavits stating the facts upon which

the liability or defense is based.”11

8 OCGA § 9-11-11.1 (b) (1). 9 See Wilkes & McHugh, P.A. v. LTC Consulting, L.P., 306 Ga. 252, 261 (830 SE2d 119) (2019). 10 (Citations and punctuation omitted.) ACLU, Inc. v. Zeh, 312 Ga. 647, 650 (1) (a) (864 SE2d 422) (2021), quoting id. at 261-262 (1) (a). 11 OCGA § 9-11-11.1 (b) (2).

5 On appeal, we review de novo the trial court’s ruling on an anti-SLAPP motion

to strike or dismiss. “We also remain mindful of the General Assembly’s directive to

construe the statute ‘broadly’ to accomplish its declarations.”12

Turning to this case, we must first determine whether Trivedi’s comments

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