This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
An energy company, Avangrid, Inc., filed a complaint against Security Limits, Inc. and its CEO, Paulo Silva, alleging defamation, tortious interference with contract, and prima facie tort. The claims were based on public comments made by the defendants to the New Mexico Public Regulation Commission (PRC) opposing Avangrid's proposed merger with PNM Resources, Inc. Avangrid alleged that these comments were part of an extortion attempt to secure contract work from Avangrid (paras 1, 6-10).
Procedural History
- District Court, Santa Fe County: The court dismissed Avangrid's complaint under New Mexico's Anti-SLAPP statute and the Noerr-Pennington doctrine, denied Avangrid's motion to amend the complaint, and awarded attorney fees to the defendants (paras 1, 13).
Parties' Submissions
- Appellant (Avangrid, Inc.): Argued that the complaint was adequately pleaded under New Mexico's notice pleading standards, that the defendants' comments were defamatory and made in furtherance of extortion, and that the comments were both objectively baseless and subjectively improperly motivated, thus falling within the sham exception to the Noerr-Pennington doctrine (paras 12, 16).
- Appellees (Security Limits, Inc. and Paulo Silva): Argued that their public comments were protected petitioning activity under the Noerr-Pennington doctrine and that the complaint was a SLAPP suit intended to punish their exercise of First Amendment rights (para 11).
Legal Issues
- Whether the defendants' public comments were protected under the Noerr-Pennington doctrine.
- Whether the comments fell within the sham exception to the Noerr-Pennington doctrine.
- Whether the district court erred in denying Avangrid's motion to amend the complaint.
- Whether the district court erred in the amount of attorney fees awarded to the defendants.
Disposition
- The court affirmed the district court's dismissal of Avangrid's complaint.
- The court affirmed the denial of Avangrid's motion to amend the complaint.
- The court affirmed the amount of attorney fees awarded to the defendants (para 39, 42, 45).
Reasons
Per Yohalem J. (Attrep C.J. and Wray J. concurring):
The court found that the defendants' public comments were protected under the Noerr-Pennington doctrine as they were not objectively baseless. The comments had a reasonable basis in fact and law, and the PRC's decision to deny the merger for reasons similar to those raised by the defendants supported this conclusion. The court rejected Avangrid's argument for a per se exception to the Noerr-Pennington doctrine for defamatory or criminally motivated speech, emphasizing that the doctrine requires a showing of both objective baselessness and improper subjective motive. The court also found no abuse of discretion in the district court's denial of Avangrid's motion to amend the complaint, given the Anti-SLAPP statute's intent for expedited resolution. Finally, the court found no error in the amount of attorney fees awarded, noting that the district court had already reduced the fees in response to Avangrid's objections (paras 16-39, 40-45).