Skip to main content
August 2021

Ninth Circuit Unanimously Affirms First Amendment Protection for Rachel Maddow’s “Paid Russian Propaganda” Commentary

By Nathaniel L. Bach and Marissa M. Mulligan
The Court held that the Southern District of California correctly granted Defendants’ anti-SLAPP motion because Ms. Maddow’s statement that OAN “really literally is paid Russian propaganda”—in the context of her broadcast, in which she employed entertaining and hyperbolic language while commenting on a matter of public concern and fully disclosing the facts—“is well within the bounds of what qualifies as protected speech under the First Amendment.”