Jennifer Lane v. Christine H. Phares

544 S.W.3d 881 · Court of Appeals of Texas · 2018

Facts

Jennifer Lane, an operatic singer and university voice professor, sued her former student Christine Phares for defamation after Phares posted anonymous comments online alleging Lane filed lawsuits against employers, lost students, taught unhealthily, and disparaged others. The trial court dismissed Lane's claims under the Texas Citizens Participation Act (TCPA), finding Lane was a limited-purpose public figure and failed to establish actual malice. Lane appealed the dismissal.

Issue

Was Jennifer Lane a limited-purpose public figure, and if so, did she present clear and specific evidence that Christine Phares published the alleged defamatory statements with actual malice?

Holding

Yes, Jennifer Lane was a limited-purpose public figure, and she failed to produce clear and specific evidence that Phares published the defamatory statements with actual malice. The appellate court affirmed the trial court's dismissal of Lane's claims.

Rule

To defeat a TCPA motion to dismiss, a plaintiff must establish by clear and specific evidence a prima facie case for each element of their claim, including actual malice if they are a public figure. Actual malice in defamation means the defendant had knowledge of the statement's falsity or acted with reckless disregard for the truth, focusing on the defendant's attitude toward the truth, not ill will.

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Case brief last reviewed 2026-02-07. Prepared by CaseReader from the published opinion.