Sahs v. Loyola: Federal Limits on State Anti-SLAPP Laws

In the legal case Sahs v. Loyola University New Orleans, the United States Court of Appeals for the Fifth Circuit addressed whether a Louisiana anti-SLAPP statute applies in federal diversity cases. The dispute began after Luke Sahs sued the university for defamation following his arrest for stalking, an incident involving allegations of chemical threats that were later dismissed. Loyola attempted to dismiss the lawsuit using Article 971, a state law designed to quickly halt meritless litigation that chills First Amendment rights. The court determined that it held interlocutory jurisdiction to hear the appeal, despite conflicting views from other judicial circuits regarding the collateral-order doctrine. Ultimately, the judges affirmed that Article 971 cannot be used in federal court because its burden-shifting framework and discovery stays directly conflict with Federal Rules of Civil Procedure 12 and 56. Under the Rules Enabling Act, these federal procedural standards must prevail over contrary state laws when determining if a case should proceed to trial.