Shahid Buttar for Congress Committee v. Hearst Communications, Inc.

CourtDistrict Court, N.D. California
DecidedApril 25, 2022
Docket3:21-cv-05566
StatusUnknown

This text of Shahid Buttar for Congress Committee v. Hearst Communications, Inc. (Shahid Buttar for Congress Committee v. Hearst Communications, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shahid Buttar for Congress Committee v. Hearst Communications, Inc., (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 SHAHID BUTTAR FOR CONGRESS Case No. 21-cv-05566-EMC COMMITTEE, et al., 8 Plaintiffs, ORDER GRANTING DEFENDANT’S 9 MOTION TO DISMISS v. 10 Docket No. 27 HEARST COMMUNICATIONS, INC., 11 Defendant. 12 13 14 I. INTRODUCTION 15 Plaintiffs Shahid Buttar and Shahid Buttar for Congress Committee bring this action 16 against Defendant Hearst Communications, Inc. alleging defamation and a derivative violation of 17 California’s unfair competition law. Plaintiffs’ claims arise from two stories published in the San 18 Francisco Chronicle in July 2020 reporting on allegations that Buttar, then a candidate for 19 Speaker Nany Pelosi’s seat in the U.S. House of Representatives, sexually harassed an individual 20 several years earlier. The Chronicle stories summarized the substance of the allegations that the 21 individual, Elizabeth Croydon, published online in an essay on the website Medium, included 22 Buttar’s denial of those allegations, and detailed the actions undertaken in response to the 23 allegations by some of Buttar’s political supporters. 24 Now pending is Defendant’s motion to dismiss the complaint in its entirety under Fed. R. 25 Civ. P. 12(b)(6) and California’s anti-SLAPP statute. Docket No. 27 (“Mot.”). For the following 26 reasons, the Court GRANTS Defendant’s motion. 27 1 II. BACKGROUND 2 A. Factual Allegations 3 In July 2020, Plaintiff Buttar was a candidate in the November 3, 2020 general election 4 for California’s 12th U.S. Congressional District in the 2020 general election, seeking to unseat 5 U.S. Rep. Nancy Pelosi, the sitting Speaker of the House. Docket No. 1 (“Compl.”) ¶ 9. Plaintiff 6 Shahid Buttar for Congress Committee was an unincorporated organization constituting Buttar’s 7 campaign. Id. ¶ 13. 8 On July 21, 2020, an acquaintance of Buttar, Elizabeth Croydon (“Croydon”), published an 9 essay on the web site Medium.com titled “Shahid Buttar Repeatedly Sexually Harassed Me.” Id. ¶ 10 16; Docket No. 28 (“Ibarguen Decl.”), Exh. G (“Croydon Essay).1 In her essay, Croydon alleged, 11 that when she and Buttar were both living In Washington, D.C., in the early 2000s and were part 12 of the same activism and arts community, Buttar “made [her] feel uncomfortable”; “repeatedly 13 pursued [her] for sex”; and “let [her] know that he was sexually available to [her] for years.” 14 Croydon Essay at 1. Croydon described an instance roughly a decade later in which she said she 15 was “shocked and embarrassed” when, after Croydon discussed her celibacy, Buttar allegedly 16 responded with comments that Croydon wrote made her feel “degraded, nauseated, and revolted 17 that he would mock me in front of friends who looked to me as an outspoken voice for women.” 18 Id. at 1-2. Croydon concluded by expressing her opinion: “We on the left must hold ourselves to a 19 higher standard as we are committed to creating a just and equitable world, free from sexual 20 misconduct, misogyny and bullying . . . . The left can do better than Shahid Buttar.” Id. at 2-3. 21 That same day, Defendant Heart published an article in the San Francisco Chronicle, 22 written by reporter Joe Garofoli, regarding the public controversy sparked by the allegations in the 23

24 1 The Court refers to the contents of Croydon’s Essay because it is incorporated by reference to the Complaint because it is explicitly referred to and hyperlinked in the Complaint, central to 25 Plaintiffs’ claims, and Plaintiffs do not dispute the authenticity of the document. United States v. Corinthian Colls., 655 F.3d 984, 999 (9th Cir. 2011). For the same reasons, each of the 26 documents in Defendant’s Requests for Judicial Notice, Docket Nos. 28, Docket No. 33 n. 2, are incorporated by reference. To the extent Plaintiffs object to the Court taking judicial notice of 27 these documents because they do not satisfy Fed. R. Evid. 201 or contain disputed facts, see 1 Croydon Essay, titled “Shahid Buttar, Nancy Pelosi’s election opponent, accused of sex 2 harassment” (the “First Article”). Compl. ¶¶ 2, 15; Ibarguen Decl., Exh. A (“First Article”). The 3 First Article, published online at 8:19pm on July 21, 2020, included a hyperlink to Croydon’s 4 Essay, id. ¶ 45. Prior to publishing the article, Garofoli corresponded with the Buttar for Congress 5 Committee and received a statement from the committee. Id. ¶ 18. The First Article included 6 statements from Buttar denying the accusations and that, “Every survivor must be heard, and I 7 hope to be allowed the same opportunity to be heard as well. . . Sexual harassment is despicable. 8 Those who exploit structural sexism and power imbalances must be exposed. I am committed to 9 putting survivors’ interests before my own.” First Article at 2. 10 The First Article also reported on public pronouncements by two political organizations 11 that had previously endorsed Buttar’s candidacy, which said they were reevaluating their 12 endorsements in light of the allegations, and also that one local elected official reacted to the 13 allegations by having his name removed from Buttar’s website and signing “a . . . petition to 14 unendorse him.” Id. The First Article quoted Buttar’s statement in response to these political 15 consequences: “I invite their examination of the issues and our campaign welcomes any scrutiny.” 16 Id. 17 Approximately ten minutes after the First Article was published online on July 21, a Buttar 18 Campaign representative emailed reporter Garofoli offering to connect the newspaper with “some 19 people who can speak about [Mr. Buttar’s] character and other claims [Ms. Croydon] has made in 20 the past that are false – including one who alleges that she also made false claims about her 21 husband. Would you want to speak with them? We are reluctant to attack her character out of 22 respect to survivors . . . but they are willing to speak with you.” Compl. ¶ 21 (alteration in 23 original) (emphasis omitted); see also Docket No. 34 (“Email Correspondence”) at 6. That same 24 evening, a different publication, The Bay Area Reporter, published an article regarding Croydon’s 25 accusations against Buttar, and included quotations from two individuals who claimed to have 26 known Buttar in the 2000s and opined that Croydon’s allegations lacked credibility, that Buttar 27 was an individual with integrity, and that Croydon has falsely accused another lawyer of sexual 1 At 5:44 a.m. on July 22, 2020, the day after Defendant published the First Article, a 2 representative of Buttar’s campaign emailed reporter Garofoli asserting that “Ms. Croydon’s 3 allegations about Mr. Buttar were false,” and that “a number of voices had been left out” from the 4 First Article. Compl. ¶ 30. The email thanked Garofoli for his coverage, and suggested that “there 5 is a lot more to this story that we think will be illuminating.” Email Correspondence at 6. The 6 campaign representative noted that “[d]ue to time limits” the campaign “did not have time to 7 arrange” more interviews or voices to be included in the First Article, and asked Garofoli, “Can 8 we do a follow up today or soon?” Id. The email did not identify any false claims in the First 9 Article or demand any corrections or retractions. Instead, the email states, “We would like a story 10 that offers Shahid the opportunity to give his perspective here and invites others who are close to 11 this situation. We gave a limited response, but given more time, we could really tell a much 12 bigger picture. Can you advise on what opportunities might be available for that?” Id. Reporter 13 Garofoli responded to the campaign representative by suggesting that “one opportunity that might 14 be available would be an Op-Ed. Our editorial page director. . .

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