Pnc Financial Services Group, Inc. v. John W. Gibson

CourtCourt of Appeals of Georgia
DecidedMay 6, 2024
DocketA24A0268
StatusPublished

This text of Pnc Financial Services Group, Inc. v. John W. Gibson (Pnc Financial Services Group, Inc. v. John W. Gibson) 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
Pnc Financial Services Group, Inc. v. John W. Gibson, (Ga. Ct. App. 2024).

Opinion

FIFTH DIVISION MERCIER, C. J., MCFADDEN, P. J., and RICKMAN, J.

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

May 6, 2024

In the Court of Appeals of Georgia A24A0268, A24A0280. PNC FINANCIAL SERVICES GROUP, INC. v. GIBSON; and vice versa.

MCFADDEN, Presiding Judge.

These appeals concern two orders entered in John Gibson’s lawsuit against

PNC Financial Services Group, Inc. In one order, the trial court granted PNC’s

motion to dismiss Gibson’s defamation claim under Georgia’s anti-Strategic Lawsuits

Against Public Participation (“anti-SLAPP”) statute, OCGA § 9-11-11.1, but denied

PNC’s request for attorney fees under the statute. In the other order, the trial court

ordered PNC to produce certain documents to Gibson. PNC had argued that the

documents were protected by the attorney-client privilege, but the trial court held that

a fiduciary duty exception to the privilege required their disclosure. In Case No. A24A0268, PNC appeals the denial of its request for attorney fees

and the order requiring it to produce documents. We hold that the award of attorney

fees was mandatory under the anti-SLAPP statute.

As to document production, Gibson’s claim that PNC must turn over to him

documents protected by the attorney-client privilege rests on his contention that PNC

owes him fiduciary duties. We reject that contention. We hold that, because Gibson’s

individual retirement account (“IRA”) was self directed, no fiduciary duty arose; and

consequently we reject Gibson’s claim to documents protected by the attorney-client

privilege.

We reverse the trial court’s contrary rulings and remand for the trial court to

enter an award of attorney fees.

In Case No. A24A0280, Gibson appeals the grant of PNC’s anti-SLAPP

motion. We affirm that ruling.

1. Background

“We generally review a trial court’s ruling on an anti-SLAPP motion to strike

de novo, viewing the pleadings and affidavits submitted by the parties in the light most

favorable to the plaintiff (as the non-moving party).” ACLU v. Zeh, 312 Ga. 647, 652

2 (1) (c) (864 SE2d 422) (2021) (citation omitted). We review a trial court’s decision

on discovery matters for a clear abuse of discretion. See Hill, Kertscher & Wharton v.

Moody, 308 Ga. 74, 80 (2) (839 SE2d 535) (2020).

So viewed, the record shows that PNC was the custodian of Gibson’s self-

directed IRA. In relation to the investigation of an investment fund, the Securities and

Exchange Commission (“SEC”) subpoenaed PNC to produce records regarding a

particular transaction of Gibson’s. Gibson consented to PNC responding to the

subpoena. But, according to Gibson, PNC did not respond accurately.

Gibson sued PNC. In his first amended complaint, he asserted claims for

conversion of his financial records, breach of a bailment agreement, and breach of

fiduciary duty. He alleged that PNC’s breach of fiduciary duty subjected him “to false

and defamatory allegations against him by the Securities and Exchange Commission

that have been publicly disclosed on the SEC web site.”

After PNC deposed Gibson — where he testified that he was claiming in his

lawsuit that, in response to the subpoena, PNC made false statements to the SEC that

had caused him reputational harm — PNC filed a motion to dismiss Gibson’s claims

3 that PNC is liable for reputational harm. It based its motion on Georgia’s anti-SLAPP

statute, OCGA § 9-11-11.1. It sought attorney fees under section (b.1) of the statute.

About three weeks later, Gibson amended his complaint and, among other

things, removed the reference to “defamatory allegations.” But he still alleged that

PNC’s breach of its fiduciary duty subjected him to “false allegations . . . publicly

disclosed on the SEC website.”

After a hearing, the trial court granted PNC’s anti-SLAPP motion, specifying

that he was “dismiss[ing] the challenged defamation claim only, including tort

damages arising from reputational harm.” The court denied PNC’s request for

attorney fees under OCGA § 9-11-11.1 (b.1) because Gibson’s “remaining claims are

not subject to PNC’s [a]nti-SLAPP Motion, and, thus survive.”

The same day, the court entered an order requiring PNC to produce certain

documents that PNC contended were protected by the attorney-client privilege. The

court based the order on a fiduciary duty exception to the attorney-client privilege.

PNC filed this appeal, and Gibson filed a cross-appeal.

2. Anti-SLAPP

4 We first address the anti-SLAPP issues. We hold that the trial court did not err

in granting the anti-SLAPP motion, but it did err in denying PNC’s request for

attorney fees.

(a) Applicable law

Regarding dismissing a claim under the anti-SLAPP statute, the statute protects

free speech. It provides:

A claim for relief against a person or entity arising from any act of such person or entity which could reasonably be construed as an act in furtherance of the person’s or entity’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 shall be subject to a motion to strike unless the court determines that the nonmoving party has established that there is a probability that the nonmoving party will prevail on the claim.

OCGA § 9-11-11.1 (b) (1). The statutory text

makes clear that the analysis of an anti-SLAPP motion to strike involves two steps. 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.

5 ACLU, 312 Ga. at 650 (1) (a).

(b) Parties’ arguments

(i) Gibson

Gibson enumerates that the trial court erred in granting PNC’s anti-SLAPP

motion because the motion was untimely and was filed for the purpose of delay. He

also enumerates that the motion meets none of the requirements of OCGA § 9-11-11.1

and that PNC’s alleged defamatory acts do not fall within the protection of the anti-

SLAPP statute. (Gibson also enumerates that if the trial court excluded any damages

from an alleged conflict of interest or breach of fiduciary duties, the court erred. He

has not shown error. The trial court explicitly limited its dismissal order to defamation

claims.)

(A) Delay and timeliness

Gibson argues that the trial court erred by granting the anti-SLAPP motion

because it was untimely and its timing demonstrates that PNC filed it for the purpose

of delay. We disagree.

Initially, we note that OCGA 9-11-11.1 does not provide that delay is a ground

for denying an anti-SLAPP motion.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

SFM Holdings Ltd. v. Banc of America Securities, LLC
600 F.3d 1334 (Eleventh Circuit, 2010)
Douglas v. Bigley
628 S.E.2d 199 (Court of Appeals of Georgia, 2006)
Washington Road Properties, Inc. v. Home Insurance
245 S.E.2d 15 (Court of Appeals of Georgia, 1978)
Tucker v. News Publishing Co.
397 S.E.2d 499 (Court of Appeals of Georgia, 1990)
Canales v. Wilson Southland Insurance Agency
583 S.E.2d 203 (Court of Appeals of Georgia, 2003)
Hagemann v. Berkman Wynhaven Associates, L.P.
660 S.E.2d 449 (Court of Appeals of Georgia, 2008)
Lewis v. Alderman
162 S.E.2d 440 (Court of Appeals of Georgia, 1968)
Newitt v. First Union National Bank
607 S.E.2d 188 (Court of Appeals of Georgia, 2004)
Lamm Ex Rel. Ira v. State Street Bank & Trust
749 F.3d 938 (Eleventh Circuit, 2014)
St. Simons Waterfront, LLC v. Hunter, Maclean, Exley & Dunn, P.C.
746 S.E.2d 98 (Supreme Court of Georgia, 2013)
Wilkes & Mchugh, P.A. v. LTC Consulting, L.P.
830 S.E.2d 119 (Supreme Court of Georgia, 2019)
Garcia v. Shaw Industries, Inc.
741 S.E.2d 285 (Court of Appeals of Georgia, 2013)
HILL, KERTSCHER & WHARTON LLP v. MOODY
839 S.E.2d 535 (Supreme Court of Georgia, 2020)
American Civil Liberties Union, Inc. v. Zeh
864 S.E.2d 422 (Supreme Court of Georgia, 2021)
King v. King, Jr
888 S.E.2d 166 (Supreme Court of Georgia, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Pnc Financial Services Group, Inc. v. John W. Gibson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pnc-financial-services-group-inc-v-john-w-gibson-gactapp-2024.