Also Read: Joy Reid Sued for Defamation by Trump Supporter Falsely Accused of Using Racial SlursIn it, Jacobs wrote, “We hold (for the first time) that California’s anti-SLAPP statute is inapplicable in federal court because it conflicts with Federal Rules of Civil Procedure 12 and 56. We also vacate the dismissal of the defamation claim under Rule 12(b)(6).