Martinez v. Toledo CA4/1

CourtCalifornia Court of Appeal
DecidedJanuary 8, 2025
DocketD082818
StatusUnpublished

This text of Martinez v. Toledo CA4/1 (Martinez v. Toledo CA4/1) 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
Martinez v. Toledo CA4/1, (Cal. Ct. App. 2025).

Opinion

Filed 1/8/25 Martinez v. Toledo CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

CARLOS MARTINEZ, D082818

Plaintiff and Respondent,

v. (Super. Ct. No. 37-2022- 00043919-CU-DF-CTL) JOSE TOLEDO,

Defendant and Appellant.

APPEAL from an order of the Superior Court of San Diego County, Joel R. Wohlfeil, Judge. Affirmed. The Bronson Firm and Steven M. Bronson for Defendant and Appellant. No appearance for Plaintiff and Respondent.

Jose Toledo appeals the order denying his special motion to strike as a strategic lawsuit against public participation (SLAPP) the complaint Carlos Martinez filed against him for reposting on Instagram an accusation by another Instagram user that Martinez had sexually assaulted her. The superior court ruled the complaint was not a SLAPP because the reposting was not made in connection with an issue of public interest, and denied the motion. We affirm. BACKGROUND When Martinez and Ali‘ikai Chaplin were in eighth grade, they ate lunch together one day. According to Chaplin, Martinez began to look at her “oddly” and “then reached for [her] breasts and [her] genitals.” Chaplin called Martinez “a ‘creep’ ” and ran away from him, but she did not report the incident to any adult at the time. Later, when they attended the same high school, Chaplin learned other students had accused Martinez of sexual assault. She and other students created “a ‘hate page’ on Instagram” that “consisted of the story that

[Martinez] had sexually assaulted [her].”1 According to Martinez, Chaplin recounted the eighth grade incident by posting the following statement on her Instagram account: “ ‘During this lunch, [Martinez] became very touchy. We were having this conversation about I don’t know what, then he reached for my tit and my vagina.’ ” Toledo was not present during the incident but reposted Chaplin’s accusation on his own Instagram account. A petition was posted on Instagram that urged readers to participate in a protest to remove

Martinez from school, and such a protest occurred at the school.2 Based on the sexual assault accusations, Martinez was suspended from school. After an investigation, the school determined the accusations could not be proved

1 The copy of the “hate page” in the record is of poor quality. The page contained 10 posts, none of which is legible, and had 44 followers. 2 The petition stated: “We all must come together as a school and a community to have a peaceful protest to remove [Martinez] from our campus making young women and men feel uncomfortable and scared and on edge at school. A place where you should feel safe and even having a school as a safe haven.” Eleven people signed the petition. 2 and allowed him to return, but he was not allowed to march at graduation with his classmates. Martinez sued Chaplin, Toledo, and another defendant for defamation. He alleged that as part of a plan to get him expelled from school, the defendants: (1) created the Instagram “ ‘hate page’ ” that contained accusations of sexual assault against him; (2) republished the “lies” on their own accounts; and (3) organized the protest at the school. Martinez prayed for damages and other relief. Toledo filed a special motion to strike the complaint under the anti- SLAPP statute (Code Civ. Proc., § 425.16). He argued the complaint fell within the scope of the statute because “this case involves an obvious issue of public importance—sexual assault of a minor—on public forums.” Toledo further argued Martinez could not prevail on his defamation claim because federal law (47 U.S.C. § 230) immunizes Internet users from liability for republications of others’ defamatory statements and because Chaplin’s accusation against Martinez was true. In support of the motion, Toledo submitted a declaration and excerpts of deposition testimony of Chaplin, excerpts of his own deposition testimony, and purported posts on Martinez’s Instagram account about national broadcasts of news that police were going to arrest the people who had distributed false information about him. Martinez opposed the motion. He argued the lawsuit did not involve an issue of public interest within the meaning of the anti-SLAPP statute, because Toledo is not a public figure, the reposting of Chaplin’s sexual assault accusation did not affect a large number of people beyond the direct participants, and the reposting was of concern only to the parties to the lawsuit. Martinez also argued his evidence established a probability of prevailing on the defamation claim, and Toledo had presented no admissible

3 evidence in support of his defenses. The superior court’s register of actions lists declarations as having been filed as part of Martinez’s opposition, but none are included in the clerk’s transcript. In his opening brief, Toledo says Martinez submitted a declaration in which he denied he had sexually assaulted Chaplin. The superior court held a hearing and denied Toledo’s motion to strike the complaint. The court ruled Toledo’s post of Chaplin’s sexual assault accusation against Martinez was not activity protected by the anti-SLAPP statute. The court explained: “As alleged, the focus of the Instagram posts was ‘ammunition’ for another round of the private controversy between these individuals and not intended to raise public awareness on the topic of sexual assault in schools.” “Publication on the Internet does not turn otherwise private information into a matter of public interest.” DISCUSSION Toledo contends Martinez’s complaint is a SLAPP because it is based on statements he made in a public forum (a Web site accessible to the public) concerning an issue of public interest (sexual assault of a minor at school). Toledo faults the superior court for concluding otherwise by ignoring the cases he cited and citing others he says are distinguishable. Toledo also contends there is no probability Martinez will prevail on the complaint because he (Toledo) is immune from defamation liability under federal law and the statement he reposted was true. We begin with some general principles regarding anti-SLAPP motions. “The anti-SLAPP statute enables defendants to quickly terminate meritless actions against them that are based on their constitutionally protected rights to speak freely and petition for redress of grievances.” (Dziubla v. Piazza (2020) 59 Cal.App.5th 140, 147.) To that end, the statute provides: “A cause

4 of action against a person arising from any act of that person in furtherance of the person’s right of petition or free speech under the United States Constitution or the California Constitution in connection with a public issue shall be subject to a special motion to strike, unless the court determines that the plaintiff has established that there is a probability that the plaintiff will prevail on the claim.” (Code Civ. Proc., § 425.16, subd. (b)(1).) Resolution of an anti-SLAPP motion proceeds in two steps. First, a defendant moving to strike a claim must show the conduct underlying the claim is within one of the four categories of protected activity listed in Code of Civil Procedure section 425.16, subdivision (e). (Baral v. Schnitt (2016) 1 Cal.5th 376, 384, 396; Bui v.

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Bluebook (online)
Martinez v. Toledo CA4/1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martinez-v-toledo-ca41-calctapp-2025.