Cocoa AJ Holdings, LLC v. Schneider

Summary

The California Court of Appeal, First Appellate District, Division Three, affirmed an order granting Stephen Schneider’s anti-SLAPP motion against Cocoa AJ Holdings, LLC’s cross-complaint. The court held that the claims arose from Schneider’s protected litigation-related and homeowners-association-related speech and petitioning activity, and that Cocoa failed to show a probability of prevailing on its claims for intentional interference with prospective economic advantage, breach of contract, unjust enrichment, or defamation. The opinion was filed October 8, 2025, and certified for publication on October 31, 2025.

Holdings

1. All four claims in Cocoa's cross-complaint arose in part from Schneider's protected litigation-related activity and protected speech concerning matters of public interest to the GS Heritage Place fractional owners. Schneider therefore satisfied the first step of the anti-SLAPP analysis.
2. Cocoa failed to demonstrate a probability of prevailing on any claim because it relied on insufficient pleadings and evidence and did not make the required prima facie showing.
3. The settlement agreement did not establish that Schneider waived all anti-SLAPP protection, and the existence of the agreement did not permit Cocoa to prevail merely by alleging that Schneider breached it.
4. Cocoa failed to show that Schneider's alleged statements and activities breached the settlement agreement's nondisparagement or cooperation provisions.
5. Cocoa failed to show a probability of prevailing on defamation because the October 2021 letter concerning alleged Davis-Stirling Act violations was protected by the litigation privilege.

Questions Presented

1. Whether Cocoa's claims for intentional interference with prospective economic advantage, breach of contract, unjust enrichment, and defamation arose from Schneider's protected petitioning or free-speech activity under Code of Civil Procedure section 425.16.
2. Whether Cocoa demonstrated a probability of prevailing on any of its claims at the second step of the anti-SLAPP analysis.
3. Whether the settlement agreement's nondisparagement and cooperation provisions waived or otherwise precluded Schneider's anti-SLAPP protection.
4. Whether Cocoa established a probability of success on its intentional interference, defamation, breach of contract, and unjust enrichment claims.

Disposition

affirmed