Littlefield v. Littlefield - Case Brief

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Case Number: A167764
Court: California Court of Appeal, First Appellate District, Division Four
Date Filed: 2025‑08‑31

Holding

The court held that the appellants failed to satisfy their burden of demonstrating that any claim in Allison Littlefield’s petition arose from protected activity under § 425.16, so the anti‑SLAPP motion was properly denied; moreover, the motion was frivolous, entitling the plaintiff to attorney’s‑fees awards under § 425.16(c)(1).

Narrative

A probate dispute tests the limits of California’s anti‑SLAPP shield

When co‑trustees of a family ranch turned on one another, the resulting probate litigation became a proving ground for the state’s anti‑SLAPP statute. In Littlefield v. Littlefield, the California Court of Appeal clarified that a movant must identify, allegation by allegation, the precise factual predicates that qualify as protected activity before a court can strike a complaint. The decision also reinforced the court’s discretion to impose fee awards when an anti‑SLAPP motion is “totally without merit.”

Procedural backdrop

Allison J. Littlefield, a beneficiary and former manager of the Pony Tracks Ranch Trust, filed a verified petition in San Mateo County Superior Court (No. 22PRO01233) seeking removal of her brothers, Scott and David Littlefield, and their aunt, Denise Sobel, as co‑trustees. The petition alleged breaches of fiduciary duty, misuse of trust assets, conversion of personal property, and a pattern of harassment that culminated in Allison’s removal from the LLC’s board of managers.

Defendants‑appellants responded with a special motion to strike the entire petition under Code of Civil Procedure § 425.16, arguing that the relief sought—most notably an injunction prohibiting the defendants from “harassing, disparaging or defaming” Allison—implicated protected speech concerning a “public issue” (the alleged gun‑related incidents on the ranch). The trial court denied the motion, finding the defendants had not identified any protected activity. The defendants appealed; Allison cross‑appealed the denial of her request for attorney’s fees under § 425.16(c)(1).

Core factual matrix

The trust was created by the decedent, Jacques Littlefield, to hold the Pony Tracks Ranch for the benefit of his descendants. The ranch is owned by Pony Tracks Ranch LLC, of which three sub‑trusts are members; the LLC is managed by a board that originally included all co‑trustees. In 2020 Allison resumed active supervision of ranch operations, while the LLC hired Stacey Limbada as a full‑time manager. A series of confrontations ensued: Limbada accused Allison’s husband, Hiruy Amanuel, of threatening her with a weapon; Limbada reported seeing bullet holes and spent cartridges on the property; and she alleged that Amanuel had discharged firearms on the ranch.

Allison contended that the defendants failed to intervene, that they allowed Limbada’s alleged misconduct to continue, and that they used trust assets to settle Limbada’s employment claims while simultaneously removing Allison from the board as a condition of settlement. The petition sought (1) removal of the defendants as co‑trustees, (2) monetary restitution for alleged breaches, (3) declaratory and injunctive relief to restore Allison’s rights to use the ranch, and (4) an order enjoining the defendants from permitting any LLC employee to harass or defame Allison.

The anti‑SLAPP analysis

California’s anti‑SLAPP statute serves to protect “the exercise of the constitutional right of petition or free speech in connection with a public issue.” The two‑step framework requires the moving defendant first to show that the plaintiff’s claim arises from protected activity; only then does the burden shift to the plaintiff to demonstrate the claim’s legal sufficiency.

The appellate court emphasized that the first‑step burden is strictly evidentiary: the movant must point to each factual allegation that constitutes protected activity and explain how that allegation supplies an element of the plaintiff’s cause of action. The court cited Baral v. Schnitt (2016) and Bonni v. St. Joseph Health System (2021), which require an “allegation‑by‑allegation” approach for mixed causes of action.

Defendants’ motion identified only the prayer for relief—the request that the court enjoin alleged defamation—and the four causes of action in their entirety. The court found this insufficient. No specific factual predicate in the petition tied the defendants’ conduct to protected speech. The alleged gun‑related incidents, even if they involved speech about safety, were framed as private, intra‑family disputes concerning the management of trust property, not as matters of public concern. Accordingly, the defendants failed to satisfy the first‑step burden, and the anti‑SLAPP motion could not succeed.

The court also rejected the defendants’ reliance on Haight Ashbury Free Clinics (2010), which allowed a mixed cause to be struck if any portion was protected. Post‑Baral jurisprudence demands that each protected allegation be isolated; a blanket strike is impermissible when unprotected claims remain.

Frivolous‑motion finding and fee award

Under § 425.16(c)(1), a court may award attorney’s fees when a special motion to strike is “frivolous” or “solely intended to cause unnecessary delay.” The appellate court applied the Moore v. Shaw (2004) standard, which requires a determination that “any reasonable attorney would agree the motion is totally devoid of merit.”

The court concluded that a reasonable practitioner would recognize the defendants’ overreach: they sought to strike a petition that mixed fiduciary‑duty claims, conversion claims, and injunctive relief—all grounded in private trust administration. The defendants offered no legal authority linking those private claims to protected activity, nor did they cite any controlling precedent beyond the outdated Haight Ashbury line of authority. Their brief omitted Baral, Bonni, and the more recent Park v. Nazari (2023), which expressly warns that a motion lacking specific protected‑activity identification is untenable.

Given these deficiencies, the appellate court deemed the motion frivolous and ordered the trial court to award reasonable attorney’s fees to Allison on remand, also granting her costs on appeal.

Impact on probate and anti‑SLAPP practice

Littlefield delivers a two‑fold warning to litigants in probate and trust disputes. First, it reaffirms that the anti‑SLAPP statute is not a catch‑all weapon for parties seeking to dismiss private fiduciary claims. The statute’s protective scope is confined to speech that addresses matters of public interest; intra‑family trust administration, even when emotionally charged, remains outside that realm unless the plaintiff explicitly alleges protected speech as the basis for liability.

Second, the decision sharpens the procedural expectations for anti‑SLAPP motions involving “mixed” causes. Defendants must catalog each protected allegation and tie it to a specific claim element. Failure to do so invites a finding of frivolity and the attendant fee sanctions. Practitioners drafting anti‑SLAPP motions in the context of trust litigation should therefore conduct a meticulous claim‑by‑claim analysis, perhaps limiting the motion to the narrow subset of allegations that truly involve public‑issue speech (e.g., a trustee’s public advocacy on a zoning matter).

The ruling also underscores the appellate courts’ willingness to reverse fee‑award denials when the trial court’s analysis is cursory. The appellate panel noted that the trial court’s oral comments suggested a “broad‑drafted” petition but did not engage the statutory test for frivolousness. Future trial courts are likely to adopt a more rigorous, written analysis to avoid reversal.

Unresolved questions

While Littlefield clarifies the first‑step burden, it leaves open the second‑step analysis for cases where protected activity is properly identified. Should a plaintiff’s claim survive the first step, the court will still need to assess whether the underlying conduct was motivated by an attempt to chill protected speech—a factual inquiry that may be especially complex in family‑trust contexts.

Additionally, the decision raises the question of whether a trustee’s internal deliberations about safety concerns could ever be deemed a “public issue” when the trust holds land that is open to the public for recreation. The appellate court’s focus on the private nature of the dispute suggests a high bar, but future cases involving trusts that own public‑access properties may test the limits of that analysis.

Referenced Statutes and Doctrines

  • Code of Civil Procedure § 425.16 (Anti‑SLAPP statute) – §§ 425.16(a)–(e), (c)(1) (fee award provision)
  • Probate Code § 15642 (Removal of trustees)
  • Labor Code § 2802 (Employer indemnification of employee for work‑related expenses)
  • California Constitution – Free speech and petition rights (Art. I, §§ 1–2)

Key Cases Cited

  • Park v. Board of Trustees of California State University (2017) 2 Cal.5th 1057 – anti‑SLAPP procedural framework
  • Nirschl v. Schiller (2023) 91 Cal.App.5th 386 – two‑step burden analysis
  • Baral v. Schnitt (2016) 1 Cal.5th 376 – allegation‑by‑allegation requirement for mixed causes
  • Bonni v. St. Joseph Health System (2021) 11 Cal.5th 995 – striking mixed causes when protected activity is isolated
  • Haight Ashbury Free Clinics, Inc. v. Happening House Ventures (2010) 184 Cal.App.4th 1539 – earlier mixed‑cause approach (overruled)
  • Park v. Nazari (2023) 93 Cal.App.5th 1099 – denial of blanket anti‑SLAPP strike when unprotected claims remain
  • Young v. Midland Funding, LLC (2023) 91 Cal.App.5th 63 – Baral‑style motion requirements
  • Moore v. Shaw (2004) 116 Cal.App.4th 182 – definition of “frivolous” anti‑SLAPP motion
  • Wilson v. Cable News Network, Inc. (2019) 7 Cal.5th 871 – burden allocation at first step
  • Coretronic Corp. v. Cozen O’Connor (2011) 192 Cal.App.4th 1381 – protected activity must be the basis for liability
  • Hastings College Conservation Committee v. Faigman (2023) 92 Cal.App.5th 323 – distinction between protected conduct and protected remedy
  • Medical Marijuana, Inc. v. Project CBD.com (2016) 6 Cal.App.5th 602 – anti‑SLAPP denial where claims lack protected activity
  • Levy v. City of Santa Monica (2004) 114 Cal.App.4th 1252 – limits on enjoining deliberative processes
  • Hewlett‑Packard Co. v. Oracle Corp. (2015) 239 Cal.App.4th 1174 – anti‑SLAPP abuse concerns

These authorities collectively shape the appellate court’s reasoning and will guide future practitioners navigating anti‑SLAPP defenses in probate and trust litigation.