U.S. District Court, District of Utah · 2:24-cv-00458-JNP-CMR · Federal

Lichfield v. Kubler and Netflix

Granted UPEPA

Forum: U.S. District Court, District of Utah
Case number: 2:24-cv-00458-JNP-CMR
Motion decided: Sep 29, 2025
Outcome: Granted
Underlying case: The Tenth Circuit agreed with the lower court on July 27, 2026, No. 25-4135. The opinion is published, so other courts can rely on it.
Conduct at issue: A documentary series about the troubled-teen industry streamed on Netflix
Underlying claims: Defamation, defamation per se, false light, intentional infliction of emotional distress, civil conspiracy

What the court held

Judge Jill Parrish dismissed every claim under Rule 12(b)(6): the challenged statements were protected opinion or rhetorical hyperbole, the true statement about a Costa Rica arrest was absolutely privileged as true, the bulletin-board juxtaposition would not convey the alleged implication to a reasonable viewer, and the derivative claims fell with the defamation theories. The defendants moved under both California's anti-SLAPP statute and UPEPA; the court held the outcome identical under either, declined to do a choice-of-law analysis, granted relief under both, and awarded fees. The court applied the no-favorable-inferences rules from Mathews v. McCown, 2025 UT 34, on defamatory meaning and fact versus opinion. The Tenth Circuit affirmed on July 27, 2026 in a published opinion, holding that none of the three challenged segments was capable of defamatory meaning under Utah law or the First Amendment, and treating the anti-SLAPP arguments as waived.