Albanese v. Menounos

In Albanese v. Menounos (2013) 218 Cal.App.4th 923, Albanese, a celebrity stylist, alleged that she had worked with Menounos, a television personality, on the Access Hollywood set. She subsequently saw Menounos at an industry event, where Menounos "'loudly accused Albanese of stealing by claiming, "Dolce and Gabbana won't lend to me anymore because they said you never returned anything."'" (Id. at p. 926.) Albanese sued Menounos for defamation and related torts, and Menounos filed an anti-SLAPP motion, urging that the complaint arose from conduct in furtherance of the exercise of the constitutional right of free speech in connection with an issue of public interest. (Id. at p. 927.) The trial court denied the motion, and Menounos appealed. The Court of Appeal affirmed. Although it acknowledged some public interest in Albanese based on her work as a celebrity stylist and style expert, it found there was "no evidence of a public controversy concerning Albanese, Menounos, or Dolce and Gabbana." The court explained: "Even if Albanese is rather well known in some circles for her work as a celebrity stylist and fashion expert, there is no evidence that the public is interested in this private dispute concerning her alleged theft of unknown items from Menounos or Dolce and Gabbana. In short, there is no evidence that any of the disputed remarks were topics of public interest." (Albanese, supra, 218 Cal.App.4th at p. 936.)