In Jakes v. Youngblood, (WD PA, April 25, 2025), a Pennsylvania federal district court refused to dismiss under Pennsylvania's anti-SLAPP law a defamation suit brought by megachurch pastor T.D. Jakes against convicted sex offender Duane Youngblood. Jakes sued after Youngblood in a podcast accused Jakes of grooming and sexually abusing him some 40 years earlier when Youngblood was 18 to 19 years old. Anti-SLAPP laws are designed to allow rapid dismissal of suits filed to suppress protected speech. The court, applying the Erie doctrine, held that the Pennsylvania anti-SLAPP law is procedural and thus does not apply to diversity cases in federal court. Instead, dismissal is governed by Federal Rules of Civil Procedure, Rules 12 and 56. The court said in part:
The Court does not believe that a procedural rule protecting a substantive right is, by virtue of the right it is protecting, transformed into a substantive law. The statute exists to spare those who exercise their free speech rights from unwarranted and harassing litigation. However, §8340.15 pursues this policy goal through procedural means.
Christian Post reports on the decision.
