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Thomas Christopher Retzlaff v. Jason Lee Van Dyke

Paid petition · United States Court of Appeals for the Fifth Circuit, No. 18-40710 · judgment October 22, 2019


Certiorari denied · October 13, 2020
Pre-decision estimate: 20% cert probability (95% interval 15%–26%)

Before the decision, about 4.8× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a Fifth Circuit decision below, and a circuit split argued in the petition.

Question presented

Texas enacted the Texas Citizens Participation Act (“TCPA”) to “encourage and safeguard the constitutional rights of persons to petition, speak freely, associate freely, and otherwise participate in government to the maximum extent permitted by law and, at the same time, protect the rights of a person to file meritorious lawsuits for demonstrable injury.” Tex. Civ. Prac. & Rem. Code Ann. § 27.002 (West 2015). Like other States’ anti-SLAPP (“Strategic Litigation Against Public Participation”) statutes, it creates “a speedy [way] for resolving litigation that may impinge on a party’s exercise of th[ese] rights.” Klocke v. Watson, 936 F.3d 240, 244 (5th Cir. 2019). The question presented is: Whether under the doctrine of Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), state anti-SLAPP statutes apply in federal diversity cases, as the First, Second, and Ninth Circuits hold, or do not apply, as the Fifth, Tenth, Eleventh, and D.C. Circuits hold.

Counsel of record

For petitioner
Daniel Roy Ortiz

For respondent
Marc John Randazza
Randazza Legal Group

Case

Conference history
Distributed for 3 conferences

Linked docket
19A930

Proceedings

  1. Oct 13 2020
    Motion for leave to file amici brief filed by 16 Media Organizations and Advocacy Groups GRANTED.
  2. Oct 13 2020
    Petition DENIED.
  3. Oct 05 2020
    DISTRIBUTED for Conference of 10/9/2020.
  4. Aug 05 2020
    DISTRIBUTED for Conference of 9/29/2020.
  5. Aug 04 2020
    Reply of petitioner Thomas Christopher Retzlaff filed. (Distributed)
  6. Jul 17 2020
    Motion to delay distribution of the petition for a writ certiorari until August 5, 2020, granted.
  7. Jul 16 2020
    Motion of petitioner to delay distribution of the petition for a writ of certiorari under Rule 15.5 from July 22, 2020 to August 5, 2020, submitted to The Clerk.
  8. Jul 08 2020
    Motion for leave to file amici brief filed by 16 Media Organizations and Advocacy Groups.
  9. Jul 07 2020
    Brief of respondent Jason Lee Van Dyke in opposition filed.
  10. Jun 26 2020
    Blanket Consent filed by Petitioner, Thomas Christopher Retzlaff
  11. Jun 08 2020
    Response Requested. (Due July 8, 2020)
  12. May 26 2020
    DISTRIBUTED for Conference of 6/11/2020.
  13. May 22 2020
    Waiver of right of respondent Jason Lee Van Dyke to respond filed.
  14. May 04 2020
    Petition for a writ of certiorari filed. (Response due June 8, 2020)
  15. Feb 21 2020
    Application (19A930) granted by Justice Alito extending the time to file until April 3, 2020.
  16. Feb 12 2020
    Application (19A930) to extend the time to file a petition for a writ of certiorari from March 4, 2020 to April 3, 2020, submitted to Justice Alito.