De Leon v. Leon CA2/2

California Court of Appeal·Decided August 24, 2026·No. B341428·Unpublished

Opinion

Filed 8/24/26 De Leon v. Leon CA2/2 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

SECOND APPELLATE DISTRICT

DIVISION TWO

KEVIN DE LEON, B341428

Plaintiff and Respondent, (Los Angeles County Super. Ct. No. 23STCV24461)

v.

SANTOS LEON et al.,

Defendants and Appellants.

APPEAL from an order of the Superior Court of Los Angeles County, Stephen P. Pfahler, Judge. Affirmed.

Law Offices of Pflaster & Berman, Martin R. Berman; LA SuperLawyers and William W. Bloch for Defendant and Appellant Santos Leon.

McCoy Leavitt Laskey and Manuel S. Boxler for Defendant and Appellant Karla Vasquez.

Geragos & Geragos, Mark Geragos and Kimberly Casper for Plaintiff and Respondent.

Plaintiff Kevin de Leon brought this action against Santos Leon, Karla Vasquez, and a number of Doe Defendants (collectively, Defendants) for invasion of privacy and negligence after a recording was published online of an October 2021 meeting Plaintiff attended with other prominent Los Angeles political figures. Leon and Vasquez appeal the trial court’s order denying their Code of Civil Procedure section 425.161 special motions to strike the complaint. We affirm.

FACTUAL BACKGROUND

We take our facts from Plaintiff’s complaint and the declarations of Leon and Vasquez. Plaintiff was a Los Angeles City Councilmember when, in October 2021, he attended a meeting in a private conference room at the headquarters of the Los Angeles County Federation of Labor, AFL-CIO, with the President of the Federation, the Council President, and another Council member. An audio recording of the meeting was made without the knowledge of any of the four attendees. Plaintiff alleges Defendants surreptitiously recorded the meeting. Leon and Vasquez, a married couple employed at the Federation, deny doing so.

According to Plaintiff, the meeting attendees discussed how to redraw Los Angeles political boundaries after the 2020 census to represent the city’s evolving demographics, including its Latino and African-American populations.

According to Vasquez and Leon, the meeting attendees “were trying to illegally rig the redistricting process” and “engag[ed] in racial stereotyping.” Some of the attendees made

1 Undesignated statutory references are to the Code of Civil Procedure.

“highly offensive” comments, including “racist attacks on other members of the City Council.”

Plaintiff did not learn of the recording until a year later, when a Twitter account alerted reporters to its presence on Reddit, “a social news aggregator and discussion website where users can anonymously upload content for other users to comment on.” According to Plaintiff, the publication of the recording in October 2022 was timed “to kneecap [his] political integrity and character and inflict maximum damage on his reputation.”

The recording generated national news and became “a very significant issue of public interest.” Plaintiff alleged Defendants uploaded the recording. Leon denied recording the meeting or uploading “the original recording.” Vasquez denied recording the meeting and claimed she first learned of it when her boss told her to read the news about it. Her opening brief says she “emphatically denied all . . . accusations” that she recorded the meeting or publicly released it on Reddit. However, Leon and Vasquez both admitted having “many communications” about the recording after it became public.

The Los Angeles Police Department initiated a criminal investigation. (See Pen. Code, § 632, subd. (a).) Some employees of the Federation, including Defendant Leon, were required to turn over their employer-issued cell phones and laptops. Police executed a search warrant at the home of Leon and Vasquez and seized Vasquez’s cell phone, laptop computer, and other electronic equipment. Police uncovered “some evidence that a computer at [Leon and Vasquez’s] residence . . . may have had a record of posting a copy of the recording . . . in September 2022 and

October 2022.” Leon and Vasquez were not charged with any crime.

Defendant Leon was fired by the Federation because there was a copy of the recording on his computer and he “discuss[ed] it with other people.” Vasquez resigned.

PROCEDURAL HISTORY

Plaintiff filed this complaint in October 2023. He alleged Defendants surreptitiously recorded the October 2021 meeting in violation of Penal Code sections 632 and 637.2. He asserted three causes of action: invasion of privacy; negligence; and negligence per se.

In May 2024, Leon and Vasquez each moved to strike the complaint pursuant to section 425.16—widely known as an “anti- SLAPP motion.” (Rusheen v. Cohen (2006) 37 Cal.4th 1048, 1055.) They argued the complaint arose from their “discussions and written communications” about the October 2021 meeting, which was activity protected by the anti-SLAPP statute. They also argued that while the complaint alleged Defendants engaged in “illegal activity in secretly recording” the October 2021 meeting, that allegation is “mixed in with allegations that [Defendants] engaged in clearly protected petitioning activity, participating in discussions and sharing of information on a matter of public interest.” Finally, they argued Plaintiff could not show a probability of success on his claims because he had insufficient evidence either one of them had made the recording.

After hearing argument, the trial court denied both anti-

SLAPP motions. The court first determined the complaint “categorically and undisputably arises from” unprotected activity–to wit, “the alleged illegal recording of the meeting between [Plaintiff] and the other[s].” While the court

acknowledged Leon and Vasquez denied any involvement in the recording, that “in no way alters the finding of . . . illegal conduct for purposes of considering the application of the special motion to strike.” The court thus determined Leon and Vasquez failed to carry their burden at the first step of the anti-SLAPP test. In the alternative, even assuming Leon and Vasquez had succeeded in the first step of the test, the court further concluded Plaintiff had demonstrated a sufficient probability of success on the merits of his claims.

Leon and Vasquez timely appealed.2 (See § 904.1, subd. (a)(13); Cal. Rules of Court, rule 8.104(a)(1)(B).)

DISCUSSION

The anti-SLAPP statute “provides a procedure for weeding out, at an early stage, meritless claims arising from protected activity.” (Baral v. Schnitt (2016) 1 Cal.5th 376, 384, italics omitted (Baral); see also § 425.16, subd. (b)(1).) A court’s analysis of an anti-SLAPP motion proceeds in two steps. (Baral, at p. 384.) “First, the defendant must establish that the challenged claim arises from activity protected by section 425.16.” (Ibid.) “[T]he moving defendant bears the burden of establishing that the challenged allegations or claims ‘aris[e] from’ protected activity in which the defendant has engaged.” (Park v. Board of Trustees of California State University (2017) 2 Cal.5th 1057, 1061 (Park); see also § 425.16, subd. (b)(1).)

2 Footnotes in Leon’s and Vasquez’s opening briefs ask us to judicially notice election records, copies of which have not been provided. Because the requests do not comply with the California Rules of Court, we deny them. (See Kao v. Joy Holiday (2020) 58 Cal.App.5th 199, 204, fn. 3 [denying request for judicial notice made in a brief]; see Cal. Rules of Court, rule 8.252(a).)

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