The Fifth Circuit Court of Appeals ruled on September 11, 2026, that Louisiana's anti-SLAPP statute, which is designed to protect individuals from lawsuits that aim to silence free speech, does not apply in federal court. This decision stems from a case involving Luke Sahs, a former student of Loyola University New Orleans, who sued the university for defamation after being accused of stalking and making threats. The ruling affects how defamation claims can be pursued in federal court, particularly in cases involving free speech.
Luke Sahs, who attended Loyola University New Orleans, found himself at the center of a legal dispute after a school-sponsored trip to Honduras in February 2023. Upon returning, a fellow student accused him of stalking and reported him to the New Orleans Police Department (NOPD). This led to an arrest warrant for misdemeanor stalking, although the charges were later dismissed in January 2024. Following his arrest, statements made by a Loyola police officer to a student reporter were published in the university's newspaper, which included serious allegations against Sahs.
In February 2024, Sahs filed a lawsuit against Loyola University, claiming defamation and several other related charges, including slander and negligence. The university responded by filing a special motion to strike Sahs' complaint under Louisiana's anti-SLAPP statute, which aims to prevent lawsuits that infringe on free speech rights. However, the district court denied this motion, stating that the anti-SLAPP statute does not apply in federal court.
The case then moved to the Fifth Circuit, where the judges were tasked with determining whether Louisiana's anti-SLAPP statute could be applied in federal court. The court ultimately affirmed the district court's decision, stating, "We hold that it does not." This ruling was based on the finding that the anti-SLAPP statute conflicts with federal procedural rules.
The court's opinion highlighted the differences between Louisiana's anti-SLAPP statute and federal rules of civil procedure, particularly regarding the requirements for dismissing a case before trial. The judges noted that Louisiana's statute imposes additional burdens on plaintiffs that are not found in federal law. This ruling aligns with previous decisions from other circuits, which have found that various state anti-SLAPP statutes cannot be applied in federal court due to similar conflicts.
The implications of this ruling are significant for future defamation cases in federal court. It clarifies that individuals cannot use Louisiana's anti-SLAPP protections in federal lawsuits, potentially making it more challenging for defendants in such cases to seek early dismissal based on free speech claims. This decision may influence how similar cases are handled in the future, as it sets a precedent regarding the applicability of state anti-SLAPP statutes in federal courts.
Moving forward, the ruling leaves open the possibility of further appeals, but it establishes a clear stance on the application of Louisiana's anti-SLAPP law in federal court. This decision could also prompt other states to reevaluate their anti-SLAPP statutes and their applicability in federal cases. As the legal landscape continues to evolve, this ruling will likely be a reference point for future cases involving defamation and free speech.