Connecticut

Although there is no statute in Connecticut addressing SLAPP suits, the state’s intermediate appellate court discussed the nature of the causes of action in a case that arose from the defendant’s act of filing a complaint against the plaintiff-attorney with the state Bar grievance committee. Field v. Kearns, 682 A.2d 148 (Conn. App. Ct. 1996). In addressing a friend-of-the-court brief’s suggestion that the plaintiff’s lawsuit was essentially a SLAPP suit, the court noted that “[t]he distinctive elements of a SLAPP suit are (1) a civil complaint (2) filed against a nongovernment individual (3) because of their communications to government bodies (4) that involves a substantive issue of some public concern.” According to the court, “[t]he purpose of a SLAPP suit is to punish and intimidate citizens who petition state agencies and have the ultimate effect of ‘chilling’ any such action.” Although it stopped short of deciding whether the plaintiff’s actions constituted a SLAPP suit, the court agreed that “if bar grievants were not absolutely immune from liability for the act of filing a grievance . . . it would have a chilling result.”

Moreover, two different Connecticut trial court opinions adopted a standard requiring a SLAPP suit, in order to be identified and dismissed as such, to be “objectively baseless in that no reasonable litigant could realistically expect success on the merits and . . . conceal[ing] an effort to interfere improperly with the defendant’s rights.” Royce v. Willowbrook Cemetery, Inc., No. XO8CV010185694, 2003 WL 431909 (Conn. Super. Ct. Feb. 3, 2003); Arigno v. Murzin, No. CV960474102S, 2001 WL 1265404 (Conn. Super. Ct. Oct. 2, 2001).