A Florida appeals court has ruled against Univision Communications Inc. in a defamation case brought by Carlos Enrique Luna Lam and his church, Iglesia Cristiana Casa de Dios. The court dismissed Univision's appeal regarding a motion related to Florida's Anti-SLAPP statute, which is designed to protect free speech. This ruling is significant as it clarifies the limits of appeals in cases involving Anti-SLAPP motions.
The case, officially known as Univision Communications, Inc. v. Carlos Enrique Luna Lam (Docket No. 3D2026-0214), stems from a defamation lawsuit filed by Lam against Univision. The court's decision affects not only the parties involved but also sets a precedent for future cases regarding the Anti-SLAPP statute in Florida.
Background
Univision is the defendant in a defamation action initiated by Lam, who claims that the network published false statements about him, alleging he received money from a drug cartel to build his church. The case has a lengthy history, with multiple motions and appeals. In September 2022, a trial court denied Univision's motion to dismiss the case, which was based on the Anti-SLAPP statute. This denial was not immediately appealable, leading Univision to seek certiorari review.
In March 2025, the Florida Supreme Court amended the appellate rules to allow for interlocutory appeals of nonfinal orders that deny Anti-SLAPP motions. Following this change, Univision filed a motion for judgment on the pleadings in October 2025, hoping to take advantage of the new rule. However, the plaintiffs moved to strike this motion, arguing it was merely a delay tactic.
The Ruling
On August 5, 2026, the Third District Court of Appeal ruled against Univision, stating that the trial court acted within its rights when it struck Univision's motion for judgment on the pleadings. The court explained that the order did not deny the motion but rather struck it, which is not subject to appeal under the new rule. Chief Judge Scales noted, "The Order is not a final appealable order and does not fall into one of the categories of non-final appealable orders set forth in Rule 9.130 of the Florida Rules of Appellate Procedure."
The court dismissed Univision's appeal for lack of jurisdiction and denied its petitions for extraordinary relief, which sought to compel the trial court to rule on the merits of the motion. The judges involved in the ruling included Chief Judge SCALES and Judges LOGUE and GORDO.
Impact
This ruling has significant implications for future cases involving the Anti-SLAPP statute in Florida. It clarifies that a motion struck by the trial court does not allow for an interlocutory appeal, thereby limiting the avenues available for defendants seeking immediate review of such motions. This decision may discourage parties from filing successive motions under the Anti-SLAPP statute if they believe their motions could be struck rather than adjudicated.
Moreover, the ruling emphasizes the importance of adhering to procedural rules and highlights the court's discretion in determining whether a motion is filed in good faith or merely to delay proceedings. This could influence how attorneys approach similar cases in the future, particularly regarding the timing and substance of motions filed under the Anti-SLAPP statute.
What's Next
Univision may seek further review of this ruling, potentially appealing to the Florida Supreme Court. However, given the court's clear articulation of the procedural issues involved, it remains uncertain whether an appeal would be successful. There are no related cases pending that could directly impact this ruling.