Reintegrative Therapy Association, Inc. v. Kinitz

CourtDistrict Court, S.D. California
DecidedSeptember 26, 2022
Docket3:21-cv-01297
StatusUnknown

This text of Reintegrative Therapy Association, Inc. v. Kinitz (Reintegrative Therapy Association, Inc. v. Kinitz) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reintegrative Therapy Association, Inc. v. Kinitz, (S.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 REINTEGRATIVE THERAPY ) Case No.: 3:21-cv-1297-BEN-BLM ASSOCIATION, INC., a California ) 12 corporation; and DR. JOSEPH ) ORDER: 13 NICOLOSI JR., an individual, ) (1) GRANTING DEFENDANT ) TRAVIS SALWAY’S MOTION TO 14 Plaintiffs, ) DISMISS; 15 v. ) ) (2) GRANTING DEFENDANT 16 DAVID J. KINITZ, an individual; and ) DAVID J. KINITZ’S MOTION TO TRAVIS SALWAY, an individual, 17 ) DISMISS; AND Defendants. ) 18 ) (3) DENYING AS MOOT 19 ) PLAINTIFFS’ EX PARTE ) APPLICATION TO BIFURCATE 20 ) DEFENDANT SALWAY’S ANTI- 21 ) SLAPP MOTION ) 22 ) [ECF Nos. 9, 10, and 30] 23 24 I. INTRODUCTION 25 Plaintiffs Reintegrative Therapy Association, Inc. (“RTA”) and Dr. Joseph Nicolosi 26 Jr. (“Dr. Nicolosi”) (collectively, “Plaintiffs”) bring this action for defamation and 27 injunctive relief against Defendants David J. Kinitz (“Kinitz”) and Dr. Travis Salway (“Dr. 28 Salway”) (collectively, “Defendants”). ECF No. 1. Before the Court is: (1) Dr. Salway’s 1 Motion to Dismiss; (2) Kinitz’s Motion to Dismiss; (3) Dr. Salway’s Anti-SLAPP Motion; 2 (4) Kintiz’s Anti-SLAPP Motion; and (5) Plaintiffs’ Ex Parte Application to Bifurcate the 3 Anti-SLAPP Motion. ECF Nos. 9, 10, 30. The Motions were submitted on the papers 4 without oral argument pursuant to Civil Local Rule 7.1(d)(1) and Rule 78(b) of the Federal 5 Rules of Civil Procedure. See ECF Nos. 25, 33. After considering the papers submitted, 6 supporting documentation, and applicable law, the Court GRANTS both Motions to 7 Dismiss for lack of personal jurisdiction and DENIES as moot Defendants’ Anti-SLAPP 8 Motions and Plaintiffs’ Ex Parte Application to Bifurcate. 9 II. BACKGROUND 10 Plaintiffs bring this suit alleging defamation based on statements made in a scholarly 11 journal article authored by Defendants and published by a third-party non-defendant. 12 A. Statement of Facts1 13 RTA is a California 501(c)(3) non-profit corporation “that offers training in 14 Reintegrative Therapy® psychological services to mental health professionals who treat 15 individuals seeking healing from addiction and trauma.” Compl. at 2,2 ¶ 7. “Dr. Nicolosi 16 is the founder and president of the board of the [RTA], and is a licensed clinical 17 psychologist serving as the clinical advisor for the [RTA].” Id. at 2, ¶ 8. 18 Defendants co-authored an article titled The Scope and Nature of Sexual Orientation 19 and Gender Identity and Expression Change Efforts: A Systematic Review Protocol (the 20 “Article”). Id. at 3, ¶ 9; see also Ex. 1 to Compl. Plaintiffs attach the Article to their 21 Complaint as Exhibit 1. Plaintiffs allege that “[o]n or around January 8, 2021, the 22 Defendants caused the . . . Article to be published in the ‘Systematic Reviews’ journal, 23 which is an online-only open access medical journal published by BioMed Central 24

25 1 The majority of the facts set forth are taken from the Complaint, and for purposes of ruling on the instant Motions to Dismiss, the Court assumes the truth of the allegations pled 26 and liberally construes all allegations in favor of the non-moving party. Manzarek v. St. 27 Paul Fire & Marine Ins. Co., 519 F.3d 1025, 1031 (9th Cir. 2008). 2 Unless otherwise indicated, all page number references are to the ECF-generated 28 1 (“BMC”).” Compl. at 10, ¶ 20. Plaintiffs allege that the Article contains the following 2 defamatory statements: 3 “What are conversion therapy and SOGIECE?[3] 4

5 “Conversion therapy,” sometimes referred to as “reparative therapy,” “reintegrative therapy,” or “reorientation therapy,” refers to a set of pseudo- 6 scientific, discredited practices that aim to deny and suppress the sexual 7 orientations, gender identities, and/or gender expressions of sexual and gender minorities (SGM). Conversion therapy ranges from talk-“therapies” 8 to invasive treatments such as eclectic [sic] shock therapies [1]. 9 … 10 SOGIECE are ineffective, harmful, and often lead to poor psychosocial outcomes. For example, SOGIECE have been associated with poor self- 11 esteem, internalized stigma and discrimination, self-harm, self-hatred, 12 depression, anxiety, and adaptive substance use (i.e., as a form of coping or suppression) [2, 14]. More generally, SOGIECE can lead to isolation from 13 both communities of origin and SGM [sexual and gender minorities] 14 communities, as many survivors of SOGIECE feel that they have lost years of their lives and are not able to embrace their authentic selves [12, 15]. Most 15 alarmingly, it is estimated that over a third of those who experience SOGIECE 16 attempt suicide [2], a statistic that does not capture those who have died of suicide.” 17 18 Id. at 11, ¶ 20; see also Ex. 1 to Compl. at 24–25. Plaintiffs allege that the statements are 19 false and defamatory, because “Reintegrative Therapy® does not seek to change a person’s 20 sexual orientation” and instead, “uses evidence-based interventions designed to resolve 21 traumas and addictions.” Compl. at 4, ¶ 15. Plaintiffs claim that “Reintegrative Therapy® 22 may not accurately be characterized as a Sexual Orientation Change Effort, or as a Sexual 23 Orientation and Gender Identity and Expression Change Effort, commonly referred to by 24 the acronyms SOCE and SOGIECE or by the pejorative term ‘conversion therapy.’” Id. at 25 4, ¶ 16. Plaintiffs allege that Reintegrative Therapy® is not a discredited pseudo-scientific 26

27 3 The Article defines: (1) SOGIECE as sexual orientation and gender identity and expression change efforts; and (2) SGM as sexual and gender minorities. Ex. 1 to Compl. 28 1 practice, given the qualifications, training, certifications, and ethical requirements 2 associated with becoming a Reintegrative Therapy® practitioner. Id. at 12, ¶ 24. 3 Plaintiffs further claim that the “citation supporting the alleged statement about 4 Reintegrative Therapy® does not even mention the term ‘Reintegrative Therapy®,’ falsely 5 representing the cited source and, thereby, evidencing that Defendants consciously and 6 deliberately added the term ‘Reintegrative Therapy’ with the intent of harming Plaintiffs.” 7 Id. at 13–14, ¶ 26. Plaintiffs further allege that “Defendants are political activists, not 8 independent researchers” and cite to: (1) a personal story by Kinitiz about how he survived 9 conversion therapy; and (2) a bill in Canada seeking to criminalize “conversion therapy” 10 for which Dr. Salway is an advocate. Id. at 14, ¶ 27. 11 Plaintiffs allege that “familiarity with the term Reintegrative Therapy® necessarily 12 implies knowledge of and familiarity with Dr. Nicolosi and the [RTA]” and therefore, the 13 statements “regarding Reintegrative Therapy® necessarily must be understood as referring 14 to Plaintiffs by clear implication.” Id. at 18, ¶ 40. Plaintiffs support this allegation by 15 stating that two people read the Article and understood it as referring to Plaintiffs, including 16 “William Stanus, a Canadian therapist with whom the Plaintiffs are familiar” and “Laura 17 Haynes, a licensed clinical psychologist living in California.” Id. Plaintiffs allege the 18 Article harms their reputation and “falsely imputes on Plaintiffs’ Reintegrative Therapy® 19 trademark and mental health practice, [a] severe, negative stigma . . . .” Id. at 18, ¶ 41. 20 B. Procedural History 21 Plaintiffs filed a Complaint against Defendants on July 20, 2021, alleging 22 defamation per se and seeking both money damages and injunctive relief. Compl. at 1, 21. 23 On October 14, 2021, Dr. Salway filed a Motion to Dismiss and Anti-SLAPP Motion to 24 Strike. ECF No. 9 (“Motion I”). On October 21, 2021, Plaintiffs filed an Ex Parte 25 Application to Bifurcate the Anti-SLAPP Motion and deny it without prejudice. ECF No. 26 10. Between September 30, 2021 and May 10, 2022, Plaintiffs filed several Motions 27 seeking to extend the deadline to serve Kinitz.

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Reintegrative Therapy Association, Inc. v. Kinitz, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reintegrative-therapy-association-inc-v-kinitz-casd-2022.