Banks v. Hoffman

Summary

The en banc District of Columbia Court of Appeals considers whether the D.C. Council exceeded its authority under the Home Rule Act by enacting the District’s Anti-SLAPP Act. The court holds that the Act’s discovery-limiting provisions do not amend Title 11, directly conflict with it, or fundamentally alter the organization, jurisdiction, or powers of the District’s courts. The opinion emphasizes the Council’s broad legislative authority and construes the Home Rule Act’s Title 11 limitation narrowly.

Holdings

1. The D.C. Council did not exceed its authority by enacting the Anti-SLAPP Act because the Act does not alter the organization or jurisdiction of the District's courts, divest them of rulemaking authority, run directly contrary to Title 11, or fundamentally alter or micromanage court procedures.
2. The Anti-SLAPP Act does not modify or displace the Superior Court's procedural rules within the meaning of Title 11.
3. The Home Rule Act does not require the District of Columbia Court of Appeals to police the substantive-law/procedural-rule distinction used by federal courts applying Erie.

Questions Presented

1. Whether the D.C. Council exceeded its authority under D.C. Code § 1-206.02(a)(4) by enacting the Anti-SLAPP Act's discovery-limiting provisions.
2. Whether the Anti-SLAPP Act impermissibly modifies Title 11 or divests the District of Columbia courts of their rulemaking authority under D.C. Code § 11-946.
3. Whether the Home Rule Act requires the court to apply the federal substantive-law/procedural-rule distinction when evaluating the Anti-SLAPP Act.

Disposition

remanded